I am a little lost on the part of the proposed regulations with requiring escrow for existing flood customers:
I understand we will have to notify these customers that their flood insurance must now be escrowed. The OCC proposed bulletin states that "For loans outstanding on July 6th, 2014, banks must provide this notice at least 90 days before they must begin escrowing." It also states that we must begin escrowing these existing loans "with the first loan payment after the first renewal date of the borrower's flood insurance policy on or after July 6th, 2014."
So.. what if a policy expires on July 7th, 2014? We have to send that 90 day notice even BEFORE the rule is put into regualtion July 6th?
Also, is there a sample of this notice somewhere that we must send our existing customers?