The limit for an insured bank/credit union is now $10 billion, but what if a loan is located in a flood zone and an HPML? Doesn't that in effect, drop the limit to $1 billion - the exemption limit for exemption from escrow for flood insurance, or am I missing something? If the institution has to insure for flood insurance because they aren't exempt, then because the have to escrow for flood don't they have to escrow for HMPL?
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David J Mulkerin, CRCM
All opinions expressed are mine and not those of my employer and are not to be taken as legal advice.