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#2252057 - 04/08/21 07:20 PM Reg H Flood Questions
JMcGee Offline
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Joined: Sep 2020
Posts: 9
Hello,

We are having a internal talks with our business units and they are asking some interesting questions.


Here are the three questions arising from our discussions:

(1) Is a judgment lien (involuntary lien in contrast to voluntary mortgage lien) on real estate a Reg H trigger (e.g. judgment lien on real estate in a flood zone for an otherwise unsecured loan)?
(2) Does a payment plan for a loan in payment default/collection (without modification of the loan documents) constitute a MIRE event requiring new flood review?
(3) Does reinstatement of a loan (reinstating after acceleration of the indebtedness following a default) constitute a MIRE event requiring new flood review?

Any help would be appreciated!

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Flood Compliance
#2252062 - 04/08/21 07:54 PM Re: Reg H Flood Questions JMcGee
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,225
Galveston, TX
1) A judgement lien as a result of a court proceeding is not a loan.

2) & 3) If the action taken neither extends the loan maturity or increases the loan amount - no.
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