What arrangement you make is really up to the bank. If they are paying the bank under an informal arrangement, then there is not much to do. If they a paying under a formal written agreement, then you would have to decide if that action is excluded from the definition of a refinance under 1026.20(a) to avoid disclosures.
At $100 a month, I am surprised that covers the force placed flood insurance premiums or have they since purchased flood insurance. If you still hold the lien, then flood insurance is still required whether you have charged off the loan or not.
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