For numerous accounts affected by the Hurricane last year, borrowers accepted a cap and extend (capitalized the del. interest to principal and then extended the term up to 6 months). How would you handle this from a flood perspective? The bank reviewed the flood determination and if it was older than 7 years, then they ordered a new one and sent out the notice. However, 1) no matter if a new determination was ordered or not, should they have looked at the insurance policy to make sure they had enough insurance due to the capitalized interest and 2) if a new determination was ordered, should the notice have been received back signed from the borrower? Timing was of the essence to help the borrowers. Thanks for your help!

Yes to both (or at least proof of delivery) and even if the FHD was less than 7 years old, a new notice was required if in a flood zone due to the extension.

Regulators are likely to cut you some slack on some of the timing issues involved (delays in obtaining acknowledgments of receipt, for example) due to the exigencies of the situation, but you still had to step through the requirements.