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#2264366 - 01/06/22 04:10 PM Substitution of Collateral - Agricultural Parcel
MLundy Offline
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Joined: Sep 2020
Posts: 25
We have an existing Ag loan with 16 parcels of vacant land as collateral. The borrower is selling one parcel and replacing it with another, but no other changes. The note will remain "as is", and we will add a mortgage with the new parcel which is perfected by language in the existing note. We will of course be ordering a new flood determination for the new parcel, but is it necessary to order new determinations for the other existing properties since I don't believe this would constitute a MEIR event? Just want to confirm I haven't missed anything. Thank you :-)

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Flood Compliance
#2264367 - 01/06/22 04:14 PM Re: Substitution of Collateral - Agricultural Parcel MLundy
raitchjay Offline
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OK
You're never required to pull a flood determination on vacant land.
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#2264372 - 01/06/22 04:47 PM Re: Substitution of Collateral - Agricultural Parcel MLundy
MLundy Offline
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Posts: 25
All of the lenders say ag land is vacant, but frequently it isn't. We like to verify in tandem with the appraisal/eval.

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#2264373 - 01/06/22 04:48 PM Re: Substitution of Collateral - Agricultural Parcel MLundy
raitchjay Offline
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OK
Totally agree that you should verify that it's vacant through the appraisal or evaluation. But if it truly is vacant, i don't know why you'd pull a flood determination, or refer to it as "vacant" if it isn't.
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#2264374 - 01/06/22 04:53 PM Re: Substitution of Collateral - Agricultural Parcel MLundy
raitchjay Offline
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OK
I think i see what you're saying now.....you still aren't required to pull a flood determination on a (truly) vacant piece of land, so whether you are going to pull a determination is going to be based on your procedures.
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#2264375 - 01/06/22 04:55 PM Re: Substitution of Collateral - Agricultural Parcel MLundy
MLundy Offline
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Joined: Sep 2020
Posts: 25
If I asked the same question but the parcels were not vacant, they still would not need to order new determinations for the existing PINS correct?

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#2264376 - 01/06/22 04:58 PM Re: Substitution of Collateral - Agricultural Parcel MLundy
raitchjay Offline
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Joined: Oct 2009
Posts: 9,105
OK
If you aren't making, increasing, renewing, or extending the loan, then no.
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#2264382 - 01/06/22 05:14 PM Re: Substitution of Collateral - Agricultural Parcel MLundy
MLundy Offline
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Joined: Sep 2020
Posts: 25
Thank you!! Really appreciate your time :-)

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