We sold HELOC's in a branch sale and in transferring flood certs. discovered 3 HELOCs that do not have their own flood certifications. Apparently, the bank depended on the determination of the 1st mortgage years ago, but the 1st was sold in secondary market. This had never been discovered prior to the sale. My question is what is the right thing to do? Do we pull a flood certification and then transfer that to the new bank? This is assuming they are not now in a flood zone.

Any assistance would be appreciated.

How does the institution purchasing the loans want it handled? If I were the purchaser you would have to provide me with a SFHDF for the property.

That's a good question. As I understand it, we are trying to figure out what we can do before contacting the purchasing bank. If we can just pull new certs. and provide them with the SFHDF and we're through, that's what we would like to do. I believe the purchaser wants the loan.

It sounds like you were in compliance when the loan was made but have no evidence because the cert went with the other file. Is that the case? If yes, I would emphasize it with the purchasing bank and suggest an updated determination. If that shows a zone change, you have to deal with it of course.

I told the manager either way we need to have the cert. so they should probably pull it and see where we stand. If its not in a flood zone, they can just transfer the cert., if it is, then they have to deal with it.

Thanks for you input.