Our bank currently has a flood review checklist in place that we complete for all MIRE events. Due to COVID-19, we are seeing a large increase in extensions. Would we be in compliance if we implemented a temporary policy during this time to complete a condensed checklist that would essentially validate any loans that had a complete flood review/checklist in file from a MIRE event in the past 6 months? What are some other options that would help keep up with the workload while staying in compliance?

If it's your policy your concerned about, you might want your senior management/BOD approve an exemption to your policy/procedure. I have not seen any guidance from the regulators to exempt the flood determination rules yet for MIRE events. I reached out to our examiners after FEMA changed their grace period for renewal premiums from 30 days to 120 days to see if it impacted the 45 day force placement rules.

I guess I would have exactly one item on the list. Is the last FHD less than seven years old and is it based on the current map. Then give them a new notice if in a SFHA and you are extending the maturity of the loan. I might be missing the point as to what else there might be to consider?

What about escrow? For older loans prior to the requirement to escrow for flood, if you extend the maturity (a MIRE) event, we would now need to escrow, correct?

That would appear to be true.

Thanks!

Would the notice letter be required if you deferred payments but didn't extend the maturity?

No - since you're not extending (the 'E' in 'MIRE') the maturity date a new notice is not required.