Here is my scenario.
Loan A is a Freddie Mac with a balance of $103,485.34 closed in 2009
Loan B is a heloc for $25,000.00 closed in Oct 2014, nothing drawn on yet
Flood insurance amount is $107,000.00 creating a shortage of $1,485.34 in coverage.

Can the borrower request to 'freeze' the HELOC by that amount until his payments on the Freddie Mac catch him up? It will take 4 payments.

Thanks!

Based on your figures you should have a current minimum coverage of $128,500. So you are $21,500 short if you only have $107,000 in coverage.

A borrower can request the LOC be frozen or suspended at anytime but that does not negate your flood insurance coverage requirements.

Since there is no funds advanced on the HELOC you may want to review the discussion on page 33 of the rescinded Mandatory Purchase of Flood Insurance Guidelines.

I'm sorry Dan, it is supposed to read $127,000 in coverage.