We are a small bank that has never had to force place flood insurance. With all the new map changes, there are some loans that will probably need force placed flood insurance. My question is this: can we apply the forced insurance premium to the principal of the loan or do we put it in as a misc fee? If we can add to principal, are we required to give any new disclosures?

Thanks ahead for your thoughts!

Whether you can add to the principal will depend on your contract language, but most likely the language will allow it.

No new TIL notice is required since this is a "subsequent" event.

That was my thought but needed a little backing up, if you know what I mean!

Thanks so much!!