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Andy Zavoina
Opinions stated are not necessarily that of my employer.
I find that every exam (we have several types of banks, several regulators), the regulators are asking to see our flood procedures, and loan files to check for determinations and insurance.
It's a good idea to send out a memo (or have an employee meeting) to go over the coverage rules for flood hazard and the timing requirements and to stress that flood insurance is not something that can be waived if you are making, extending, increasing or renewing a loan secured by improved real property or an affixed mobile home in a flood hazard zone in a participating community.
I can e-mail it to you and you can make changes to procedures to fit your institution.
mizrahib@partnershipbanking.com
They are also looking closely at the vendors and the zones they ID compared to what is on the policy.
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Andy Zavoina
Opinions stated are not necessarily that of my employer.
Remember who is partly insured here, the government. With adequate coverage there is less paid out when a disaster occurs. This goes beyond your relationship with your customer.
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Andy Zavoina
Opinions stated are not necessarily that of my employer.
I think this is wishful thinking, certainly not worth the risk. And speaking of risk, in addition to the regulatory risk, what if developments in the area have now put this is a flood zone? If you skip a step and the property floods, who can the homeless borrower blame/seek recourse? You got it. There are several risks here.
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Andy Zavoina
Opinions stated are not necessarily that of my employer.
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Opinions expressed are my own, and do not necessarily reflect those of my employer.
The lender should take into account the fact that Congress was seriously dissatisfied with the low level of compliance and enacted the new law to clear up the problems. So, assume no grandfathering. The new requirements set a standard which absolutely must be met.
[This message has been edited by Lucy Griffin (edited 04-04-2001).]
1. The determination MUST on the NEW form, and that form did not exist in 1989.
2. The Lender must be aware that no changes have been made to the flood hazard maps that would include the property as being in a flood zone. Basically, the only way to ensure that is to have Life of Loan monitoring. (Or keep a full set of updated flood maps yourself!)
I don't understand the resistance to a procedure that costs about $10 - $20 (depending on the vendor and service requested) and only takes about 5 minutes (or less.)
You'd think we were asking the lending to eat a plate of broccoli!