if you meet the definition of small bank, but you currently do servicing for your residential portfolio under these conditions would you need to escrow under the new flood requirements?

under these conditions

What conditions??? You mean you have and service escrow accounts?

Yes, we have residential loans in our portfolio and they have escrows

Well, it is hard to say. You have to answer both questions A and B.

(A) That has total assets of less than $1 billion as of December 31 of either of the two prior calendar years; and

(B) On or before July 6, 2012:

(1) Was not required under Federal or State law to deposit taxes, insurance premiums, fees, or any other charges in an escrow account for the entire term of any loan secured by residential improved real estate or a mobile home; and

(2) Did not have a policy of consistently and uniformly requiring the deposit of taxes, insurance premiums, fees, or any other charges in an escrow account for any loans secured by residential improved real estate or a mobile home.