Hello -

§339.5(a)(1) says to escrow a consumer residential loan in a flood zone if it is made, increased, extended, or renewed on or after 1/1/16.

It does not specifically include "deferred" loans, and we are unsure if a deferral would be an escrow triggering event.
For example, we have a promo twice a year for a "skip-a-pay" deferral on the customer's loan. In turn, it pushes their maturity out by ONE MONTH longer.

Any thoughts on this? Thanks!

§339.5(a)(1) says to escrow a consumer residential loan in a flood zone if it is made, increased, extended, or renewed on or after 1/1/16.

it pushes their maturity out by ONE MONTH longer.


If you deferred (extended) the maturity date the flood rules kick in. This is why most banks exclude designated loans from skip-a-pay programs.

Any MIRE event (Make, Increase, Renew, Extend) triggers all the flood insurance requirements. New flood determination (if not within seven years or not based on current rate map), new notice to borrower of flood insurance availability, determination of adequate insurance coverage, and escrows, if applicable.

Thank you Dan!

I like the "MIRE" RLCarey!