Not sure where to post this question....here is the scenario, as briefly as possible.

Existing draw down line of credit to construct a principal residence.
Flood cert indicated that the property is NOT in a flood zone.
The construction is not complete and an extension (modification agreement)is ordered...there is still money to draw.
The remaining money will be used to construct a separate "game room" structure on the property.
A new flood cert was obtained. The new cert indicates that the proposed game room (corner of the property) is in a flood zone!!
Now, we need to require and escrow flood insurance.
Does TRID disclosures kick in due to the escrow requirement? Or do we only need to worry about the escrow disclosure?

FYI....management here does not honor the separate building exemption from flood insurance. We require it.

"Does TRID disclosures kick in due to the escrow requirement?"

Per 1026.19(e)(1)(iii), you don't have an application so no TRID.

I know your question is regarding TRID, but if your loan is 12 months or less, you may not need to require escrow yet, even with the extension.

From the Final Rule, published in the Federal Register on July 21, 2015 (emphasis mine):

The final [escrow] exception provided by section 25 of HFIAA is for a loan that has a term of not longer than 12 months, which the Agencies proposed as provided by the statute. Several financial institution commenters suggested that the term of the exception be extended to 15 months or 24 months to include all construction loans. The Agencies note the statute provides an exception only for loans with a term of 12 months or less, and therefore, the exception is adopted as proposed. However, if a loan of 12 months or less is extended or renewed for an additional term of 12 months or less, the Agencies' regulations would permit the exception to apply to the extended or renewed loan because an extension or renewal is a triggering event. Therefore, at the time of the triggering event, the regulated lending institution may apply the exception if the term of the newly extended or renewed loan is for a term of 12 months or less.

Thank you, Jen. Well.....the loan was approved for the perm, but the perm will be a brand new loan. The initial loan term was 12 months. Then we did another 12-month extension. I am not sure why, but now, with the second 12-month extension at maturity, a new flood cert was obtained. It bears a statement that an aerial view has determined that the gameroom (secondary structure) is in a flood zone. So we had the borrower obtain the insurance before executing this 3rd extension, which will be for 9 months. I suppose this meets the exception you referenced with respect to escrowing. But what causes me indigestion is the fact that the subsequent extensions were (or will be) executed well after the maturity date and backdated. Outside of the obvious legal issue about the legitimacy of the extensions, the term actually ended up being more than 12 months, depending upon whether you look at the document date or the execution date.

Grr. Don't even get me started on backdating extensions. . . like it was a surprise that the loan was about mature again?!?

Good luck!