We have a customer purchasing a rent home and pledging 16 properties to that one in lieu of a down payment.....We already have these properties pleadged to their own loans....If we cross pledge them to this new loan, do we need to obtain a recertification or an entire new flood determination

As long as the determinations are less than 7 years old, on the prescribed form and there have been no map changes then you would not need new determinations on the existing properties.

Thanks

If any of the properties were in a flood zone, would you have to deliver the notice(s) if you are cross pledging the properties to your new note?

Yes. You need a notice for each loan transaction.

And if you don't, you could get hit with CMP's for a pattern or practice of a violations.

Here's a thought for regulatory relief - if a lender has a loan secured by improved real estate located in a special flood hazard area, and the lender has a current flood insurance policy or is in the process of notifying/force placing sufficient coverage, and the lender Makes, Increases, Renews or Extends a loan on that property, the requirement to obtain a certification and notify the borrower is suspended.

I mean, really.

Amen to that Princess Romeo