Skip to content
BOL Conferences
Thread Options
#2174047 - 04/18/18 03:56 PM Escrow on HPML/flood
newyork Offline
Gold Star
Joined: Aug 2008
Posts: 452
We process mandatory escrow on all HPML loans. we do not escrow on all other loans. just HPML loans. We have an HMPL loan that is now in a flood zone due to remapping. Must we start escrowing for Flood insurance also?

Return to Top
Escrows on Higher-Priced Mortgages
#2180527 - 06/01/18 10:08 PM Re: Escrow on HPML/flood newyork
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,669
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.

Return to Top