At my bank, we allowed mortgage customers to pay their own taxes if their LTV was low and other criteria was met, we then did not have to escrow for flood. These customers will need to get the new notice if the property is located in an SFHA. Also, we did not require escrow on our first lien closed end credit home equity loans, so we will need to send the notice to any such customers whose properties are located in an SFHA. Our loan documents for home equity loans currently does not address escrow. We will consult with Legal Counsel to see what we need to do to impose a contractual requirement for escrow.
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.