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#925224 - 03/18/08 07:22 PM Abundance of Caution
Norrie Offline
Member
Joined: Feb 2008
Posts: 67
FEMA's Mandatory Purchase of Flood Insurance Guidelines (September 2007) states, "The mandatory purchase provisions apply even on those loans where real estate is secured
out of “an abundance of caution.” I am receiving pushback from management on this issue. They want to know FEMA's definition of "an abundance of caution" and compare it with their definition. Please advise.

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Lending Compliance
#925243 - 03/18/08 07:30 PM Re: Abundance of Caution Norrie
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
Abundance of Caution gets you NO WHERE, except for that if you can prove it really IS ABC, you do not have to comply with appraisal standards requirements.

so, if it is a disclosable (consumer purpose) loan, you do your normal disclosures. In addition, regardless of purpose FEMA requirments will ALWAYS apply...

The best definition of ABC and it's true qualifications will be found in your call report guidelines.
Last edited by RR joker; 03/18/08 07:30 PM.
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My opinion only. Not legal advice.

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#925263 - 03/18/08 07:42 PM Re: Abundance of Caution RR Joker
Norrie Offline
Member
Joined: Feb 2008
Posts: 67
Thank you, RR joker.

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#925334 - 03/18/08 08:21 PM Re: Abundance of Caution Norrie
Mint Julep Offline
Diamond Poster
Mint Julep
Joined: Oct 2007
Posts: 1,152
Tennessee
As I have noted before ...

They pay you to know this stuff and when you tell them something they don't want to hear, they question what you know.

Start questioning their credit decisions. When they object, ask them how it feels to be questioned about their expertise.
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Just another self-proclaimed expert ...

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