Upon reviewing FDIC FIL-32-2015 that came out yesterday,
I am still trying to digest these new flood escrow rules.
Consider these scenarios:
A) Residential Property, Rental Purpose Loan
B) Residential Property, Ag Purpose Loan
C) Residential Property, Home Equity Line of Credit
If I understand correctly, escrow of flood premiums are not mandatory on any of the above properties as of January 1, 2016, correct?
However, I believe the option to escrow flood premiums must be provided only to property C above by June 30, 2016, correct?