Thread Starter: Anonymous
Title: Re: Notice of Special Flood Hazard - Timing
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Another Anon....
Regarding the word "reasonable". Using that term leaves a lot of room for interpretation. In legal circles, the term used is, how a reasonable person would view the issue. I fully believe that was the intent when this law was written. To leave it subject to each and every situation. Yet, I continue to hear, lock step viewpoints that it's 10 days or it's late. I also think that the 10 day viewpoint is for those customers who had no idea the building is in a flood zone. Ten days gives them time to go get insurance. Yet 99% of our flood loans are home rentals where the customer often refinances the same house. Flood insurance is already in place and won't expire for another six months. Yet we get written up for having them sign the notification at closing. It's a formality. It's also reasonable in this situation. I'm tired of having this argument with auditors and examiners with this idea of "10 days or its late". I sure wish they would get with FEMA and have them articulate these situations, and give us a break. We're managing risk just fine.
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