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#2242572 - 09/16/20 09:32 PM No Escrow of Flood Ins. - Is this ok?
TeamComply Offline
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Joined: Aug 2016
Posts: 543
Bank made loan to LLC, for the purpose of refinancing and renovating an investment property (rental house), so loan is business purpose. Property is located in a flood zone and requires flood insurance. Bank has set up escrow (which we don't require or do often on business/commercial loans) for taxes and hazard insurance. Should flood insurance also have been escrowed in this situation? I believe based on the exception found at 12 cfr 22.5(2)(i): "The loan is an extension of credit primarily for business, commercial, or agricultural purposes:" that we aren't required to escrow flood insurance, however I wanted to be sure...since we do have escrow in place for taxes and hazard insurance on this particular loan. Again, not our typical practice, but something I saw when reviewing this loan file, so wanted to ask. Thanks.

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Flood Compliance
#2242585 - 09/16/20 09:54 PM Re: No Escrow of Flood Ins. - Is this ok? TeamComply
rlcarey Offline
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rlcarey
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Galveston, TX
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#2242586 - 09/16/20 09:54 PM Re: No Escrow of Flood Ins. - Is this ok? TeamComply
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
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Central City, NE
As you stated, business purpose loans are exempt from the flood insurance escrow requirements. §339.5(a)(2)(i)
This doesn't change because you escrow for other things.
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#2242587 - 09/16/20 09:57 PM Re: No Escrow of Flood Ins. - Is this ok? TeamComply
TeamComply Offline
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Joined: Aug 2016
Posts: 543
Thank you both for confirming...wanted to be sure!!!!

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