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#1997568 - 02/23/15 04:53 PM Flood Policy already in Place - 10 days?
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
If a customer already has flood insurance in place before a loan is bought to us, they obviously know its a flood zone. Do we still need that 10 day window from Flood Cert to Closing even if a policy has been in place since November 2014?

Thank you.

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Flood Compliance
#1997618 - 02/23/15 07:02 PM Re: Flood Policy already in Place - 10 days? mdog76
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You are required to provide the notice a reasonable time before closing. Ten days is an attempt to suggest what's reasonable. Under the circumstances, since the borrower already knows, a shorter period could also be reasonable. But you still have to provide the notice and obtain the borrower's acknowledgment of delivery, even if it seems silly to do so.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1997670 - 02/23/15 09:03 PM Re: Flood Policy already in Place - 10 days? mdog76
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
John is right. I just want to add, you don't need to delay closing. Get the notice out, get evidence of adequate insurance and then close the new loan.
David Dickinson

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#1999872 - 03/05/15 01:14 AM Re: Flood Policy already in Place - 10 days? David Dickinson
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
A slightly different wrinkle then... would this same hold true if you were booking an extension... i.e. send out the notice, make sure adequate flood is in place and then do extension paperwork... no need to wait 10 days?

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#1999908 - 03/05/15 02:33 PM Re: Flood Policy already in Place - 10 days? mdog76
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
The notice requirements are the same when Making, Increasing, Renewing or Extending a designated loan (MIRE). If flood insurance is already in place follow the notice and documentation procedure John and David outlined and proceed to closing.
The opinions expressed are mine and they are not to be taken as legal advice.

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