I'm somewhat confused about the new escrow requirements for flood. I read through some of the older threads and I'm still not sure that I follow.

A bank with no loans and no policies related to lending was acquired and relocated to NYC. We don't have a policy regarding escrowing for taxes and insurance. The first loan which was closed in which the Bank withheld funds in escrow was July 2014. This was a commercial loan and we have closed two more commercial loans in which the Bank withheld funds in escrow.

My reading of OCC Bulletin 2015-33 leads me to believe that the escrow requirements are not applicable to us. I would be curious as to how others look at our situation.

If you didn't have any escrows prior to 7/6/12, and you're less than $1B, you don't have to escrow beginning 1/1/16.

We're going to be explaining these rules in great detail at the Aug 26th BOL Webinar entitled "Part II Flood Insurance: Everything You Need To Know"
http://www.bollearningconnect.com

We did Part I today. If you didn't catch it, you can purchase the recording at the same link.

Thanks for the info David.