I have two questions regarding Flood Insurance:
1. The correct time frame of 7 years for the Standard Flood Hazard Determination Form is the last mapping review or the date of the determinations?
2. In commercial loans where there are multiple properties as collateral for multiple loans the policies are done by property using the sum of all loans amount? If it is possible to provide an example it would be very helpful.
We are on a loan audit at a client's bank. Loans with collateral located in a flood zone are escrowed to pay the premiums. This bank allowed a policy to expire and didn't pay the premium until 3 days after the expiration of the policy. I know I read somewhere in the new rules within the last 2 years that bank's have the responsibility of paying flood premiums timely, before the expiration of the policy. Did I dream this or is it part of the new rules? If so, where can I find it.
Does the new Homeowner Flood Insurance Affordability Act of 2014 require everyone to escrow for flood insurance?
I’ve heard that grandfathered flood insurance is going away is that true?
How do you deal with determining ongoing content coverage when you are taking something like inventory for collateral, which can change at any point in time? Do you need to get a list yearly from the customer?
Is a separate flood policy necessary for residential home and detached garage?
If we modify a loan that we are servicing and it is already in a Special Flood Hazard Area, do we have to provide another flood notification?
What is an acceptable timeframe for our flood vendor to send life of loan monitoring updates for map changes? It seems our vendor sends them out once a month, but they are dated throughout the past 30 days. Would it be acceptable to send notices to customers within 1 week of receipt of life of loan update?
If our flood vendor notifies us of a map change, does this mean we need to order a brand new flood determination?
With all the new flood map revisions we have received some changing properties that were in a flood zone to not in a flood zone. The problem is we know those properties flooded in the past. Can we still require flood insurance from the borrower on those properties? We think this is a safety and soundness issue.