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#1738567 - 09/06/12 06:33 PM Flood Determinations
ackcompliance Offline
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Joined: Nov 2009
Posts: 139
Do we need to pull flood determinations on a revolving line of credit that has been renewed when the real estate is cross collateralized with another note?

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Flood Compliance
#1738573 - 09/06/12 06:44 PM Re: Flood Determinations ackcompliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
You will either have to do that or verify the current determination is still OK (i.e., less than seven years old, etc.), every time you MIRE any loan to which is serves as collateral.
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#1738586 - 09/06/12 06:58 PM Re: Flood Determinations ackcompliance
ackcompliance Offline
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Posts: 139
Where is this found in the regulation? Do you have a link? I'm just wondering what criteria we need to check in order to determine that the current flood determination is still ok.

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#1738594 - 09/06/12 07:07 PM Re: Flood Determinations ackcompliance
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
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#1738627 - 09/06/12 07:35 PM Re: Flood Determinations ackcompliance
ackcompliance Offline
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Joined: Nov 2009
Posts: 139
thank you!

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#1738864 - 09/07/12 02:38 PM Re: Flood Determinations ackcompliance
ahkcompliance Offline
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Joined: Sep 2008
Posts: 2,474
Midwest
Just curious what other banks do when you have to pull a new determination for a extention because maps change and can't rely on the previous one. Do you charge the customer for the new determination or does your bank absorb that cost?

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#1738878 - 09/07/12 02:51 PM Re: Flood Determinations ackcompliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Probably six of one and a half dozen of the other. How often does it happen???
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1738891 - 09/07/12 03:05 PM Re: Flood Determinations ackcompliance
ahkcompliance Offline
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Joined: Sep 2008
Posts: 2,474
Midwest
Not often but we are reviewing our process and some lenders don't like the idea of charging the borrower for another determination when they paid for LOL monitoring.

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#1739298 - 09/10/12 12:29 PM Re: Flood Determinations ackcompliance
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
some lenders don't like the idea of charging the borrower for another determination when they paid for LOL monitoring

Then let the loan officer pay for it to offset the expense to the lender (bank).

If the determination is obtained due to making, increasing, renewing or extending the loan then then the borrower pays the associated expenses for the MIRE.
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The opinions expressed are mine and they are not to be taken as legal advice.

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