My understanding is that you would not have to automatically escrow for flood in this situation. A map change in and of itself does not constitute a MIRE event for purposes of the Flood Regulations. Basically, in this scenario, your duty is to offer the option to escrow the flood insurance, unless you qualify for the small lender exception, in which case you really have no responsibility other than to notify the borrower that they are now in a flood zone, require sufficient flood insurance, potentially force place, etc.