Latest Compliance - Flood Insurance Topics

Add Force Placed to Nonaccrual Collateralized?

03/10/2019

Can you add force placed insurance to a non-accrual loan that is well collateralized? State laws and the contract allow it for it.

Elevation Certificate Cost-Change in Circumstance?

02/24/2019

Is the cost of an elevation certificate a valid change in circumstance? The elevation certificate is not a requirement of the bank but it is a requirement of the insurance company. If we don't need to re-issue the loan estimate where should the fee be disclosed on the closing disclosure?

Notice letter automation for flood zones

03/12/2017

How can we automate our notice letters for flood zone loans?

Declaration Page Evidencing Coverage (Flood Rules)

01/29/2017

We have a no cashout refinance where property is in a flood zone. The way I read the flood rules, we still need a declaration page evidencing coverage and then during our ongoing monitoring of the property, we can then accept a notice of insurance coverage at that point. Is this correct?

Mortgage Impairment​ Policy

12/12/2015

The bank has a mortgage impairment​ policy that states the lender is covered in the event of a loss due to flood​ damage​ in the amount equal to the outstanding loan amount or the limits imposed by​ the flood regulation, whichever is less. Is this type of coverage​ sufficient to serve as a "force placement of flood insurance" in the event a borrower allows their flood policy to lapse and they have not responded to​ the banks request for a new policy? In the regulation it reads we have to​ force place on behalf of the borrower...the borrower is not covered in this case, only the outstanding loan amount is. I am interested in your thoughts. Also, we do not charge the borrower for any force place coverage in this situation.

Where to Find Flood Insurance Calculator

10/04/2015

Where can I find a flood insurance calculator? There was a link but it was under construction and now I can't find it.

Reg That Has Threshold for Building's Value

09/15/2014

I have a loan located in a flood zone. The appraisal is $105,000 with a $102,000 land value leaving the one building on the site a value of $3,000. I know flood insurance is not required on loans of $5,000 or less and a term of one year. Is there anything in the regulation that has a threshold for the building's value? If so, what is that value?

Biggert-Waters Reform Act: NFIP Policy

09/15/2014

Beginning this fall, in accordance with Biggert-Waters Reform Act, the NFIP will implement the requirement for agent and policyholder notification in cases where duplicate coverage is indicated. Per FEMA, when duplicate NFIP policies are issued to different named insureds for the same building, the building owner must determine which policy is to remain in effect. For example, if a tenant has purchased building coverage, the policy(ies) must either be endorsed to remove the building coverage, endorsed to include the building owner as a named insured, or canceled. My question, has there been any discussion of how Lenders will be notified of policy cancellations? Will the borrower be given adequate time to produce evidence that the required coverage is in place but through a separate policy that precedes the policy they obtained when their loan was closed? I can foresee this being an issue where a loan was made to a tenant that leases commercial space who was unaware the building owner already had coverage in place.

Issue Funds Before Flood Insurance Is In Place?

09/08/2014

Borrower is building a camp on pilings and flood insurance is not available until elevation is determined. Can any funds be issued before flood coverage is in place?

How Can We Automate the Flood Certificate Process During Loan Approval?

06/16/2014

How can we automate the flood certificate management process?