Flood Escrows

OK - I am not sure if I missed something or what, so please help!

I [/i]thought[i] commercial loans and HELOCs were exempt from flood escrow requirements, but I am reviewing some loan files and seeing escrows on all. What did I miss?

Nothing.

(ii) Exceptions. Paragraph (e)(1)(i) of this section does not apply if:

(A) The loan is an extension of credit primarily for business, commercial, or agricultural purposes;

(D) The loan is a home equity line of credit;

Thank you! I thought I was going crazy well----maybe I am.

Having an exemption for the requirement doesn't mean that you aren't permitted to escrow flood premiums for such loans.