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#2230931 - 02/12/20 10:00 PM Commercial Loan with Repetitive Flood Loss
Frosh Offline
Joined: Mar 2015
Posts: 89
A commercial loan officer's customer at my Bank has been unable to get flood insurance to purchase a home the customer would like to resell/flip in 12 months.

Several insurance companies (including the customer's typical agent) have told the Bank's customer they cannot write flood insurance because the subject property is a repetitive flood loss. The insurance companies refuse to write the policy. According to 2004 Flood Insurance Reform Act the insurance companies are correct.

Is documentation from the insurance company required in the loan application docs for repetitive flood loss, or severe repetitive flood loss?

The loan has been approved, and so, for, HMDA and Reg. B, the application should be coded as a withdrawal?

Any input would be appreciated! Thank you in advance.

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Lending Compliance
#2230939 - 02/12/20 11:24 PM Re: Commercial Loan with Repetitive Flood Loss Frosh
rlcarey Online
10K Club
Joined: Jul 2001
Posts: 81,283
Galveston, TX
Documentation is a lender issue, but yes, I would think you would want to document it. The loan is being denied for unable to provide adequate flood insurance.

Have they tried a private policy?
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