Thread Starter: Anonymous
Title: Re: Notice of Special Flood Hazard - Timing
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A new responder says: I agree with the other responses above, but wanted to elaborate that the meaning of "reasonable time before completion" means "not too short a time before loan closing." It has never been interpreted as "not too long a time before loan closing."
10 days before loan closing is reasonable adequate advance notice (and was actually the minimum number of days before closing, until a rule change in 2014 changed it from "10 days notice" to "reasonable notice"); likewise 10 months before loan closing is reasonable (as long as maps haven't changed, for instance, changing the same property from one zone to a different zone).
The intent behind "reasonable" is that it would unreasonable to wait until the morning of the closing to notify the borrower; the borrower is supposed to be given a reasonable number of days to find the flood insurance available and purchase it. It would not be reasonable to only give them 24 hours, etc. I don't think an auditor would need to waste time on why an extra amount of time was given to the borrower - that's far outside the intent of the rule - nor on why it took a given loan a long time to close, particularly if it's an isolated incident and there was no complaint by the borrower.
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