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#1188025 - 05/21/09 12:31 PM Flood Determination - req'd on mods?
Many Hats Offline
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Joined: May 2008
Posts: 915
Orlando, FL
We are doing a loan modification for a MFH w/out land (changing rate/term to lower payments for customer). Do we need to pull a new flood on modifications like these?

We have a flood we pulled when the loan was done with LOL coverage & the account number is still the same.

I say no, but wanted reassurance. smile

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Lending Compliance
#1188029 - 05/21/09 12:37 PM Re: Flood Determination - req'd on mods? Many Hats
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 46,644
Bloomington, IN
If the existing determination meets all 3 of the following you can rely on it. If it does not meet all 3 conditions and if the modification increased the loan balance or extends the maturity you will need a new determination.

The 3 conditions are:

1. The determination is on the prescribed SFHDF;

2. Is LESS than 7 years old; and

3. There have been no map changes.


PS. LOL monitoring does not insure you will be notified of a map change, only that you will be notified if there is a status change in the property.
Last edited by Dan Persfull; 05/21/09 12:40 PM.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1188051 - 05/21/09 01:11 PM Re: Flood Determination - req'd on mods? Dan Persfull
Many Hats Offline
Platinum Poster
Joined: May 2008
Posts: 915
Orlando, FL
Perfect...thanks!

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#1188574 - 05/21/09 06:29 PM Re: Flood Determination - req'd on mods? Many Hats
VRV Offline
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Joined: Jun 2007
Posts: 173
If the modification is just a change in terms (not a new loan) and doesn't increase the amount outstanding, would the need for a determination even be triggered? I have a meeting on this topic tomorrow and thought I understood the requirements, but now I'm wondering if I'm mistaken. Thanks.

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#1188684 - 05/21/09 07:40 PM Re: Flood Determination - req'd on mods? VRV
Compliance4521 Offline
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Compliance4521
Joined: Jan 2007
Posts: 533
Washington
Yes that is correct. If you are making, extending, increasing or renewing a loan then the flood determination and notice is required.

If your loan transaction does not meet that criteria, then no new determination is needed.

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