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#1124811 - 02/06/09 05:32 PM Does one escrow trigger escrow req for all flood?
Tesla Offline
Power Poster
Joined: Nov 2003
Posts: 3,726
My whole question didn't fit so here it is "Does establishing one escrow account for real estate tax purposes trigger the following:
The escrow requirement of the 1994 Reform
Act is limited to instances where a lender
establishes an escrow account for a loan for
another purpose. If financial institutions and
their servicers require the escrow of taxes,
insurance premiums, or any other fees or
charges for covered loans, they must also
escrow for premiums and fees for flood
insurance.?"

And if so, do you have to go back through your flood portfolio and require existing customer to begin escrowing?
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Lending Compliance
#1124851 - 02/06/09 05:48 PM Re: Does one escrow trigger escrow req for all flood? Tesla
Al Miller Offline
Diamond Poster
Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
The requirement is loan-by-loan. If you escrow for taxes and/or insurance and/or etc. AND the property is in a SFHA, you must also escrow for flood insurance.

"establishes an escrow account for a loan ..."

Al
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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#1124869 - 02/06/09 05:56 PM Re: Does one escrow trigger escrow req for all flood? Al Miller
Tesla Offline
Power Poster
Joined: Nov 2003
Posts: 3,726
Whew! Thanks!
_________________________
It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.

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