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#2214130 - 05/21/19 08:40 PM Flood Escrow on Subordinate Lien
BA13 Offline
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Joined: Jul 2016
Posts: 181
We have an applicant who wants to do a 2nd lien for debt consolidation. Their dwelling is located in a SFHA and coverage is in place however the 1st lien holder is not escrowing for flood insurance. If we do the subordinate financing (closed end), we would have to establish an escrow account, correct? I see the subordinate financing exemption but I'm wondering if that's assuming the 1st lienholder is already escrowing for flood??

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Flood Compliance
#2214137 - 05/21/19 09:50 PM Re: Flood Escrow on Subordinate Lien BA13
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,893
Galveston, TX
Nope - 2nd liens are exempt regardless. Escrowing would be totally up to you.
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#2214177 - 05/22/19 03:17 PM Re: Flood Escrow on Subordinate Lien BA13
BA13 Offline
100 Club
Joined: Jul 2016
Posts: 181
Thank you Randy. I reviewed that section again and it makes better sense.

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