01/25/2010
I know if we get a flood determination letter, the fee is not a prepaid finance charge, but I thought that if we got the one called Life of Loan determination, then it was prepaid. Is this correct or not?
01/11/2010
In the Guru Q & A: <a href="http://www.bankersonline.com/lending/guru2009/gurus_ldng090709d.html">Timeframe to Provide Flood Insurance</a>, it states that the time frame is forty-five days. Where can I find a citation for this?
01/04/2010
If you order a flood determination on Monday, and it comes back on Tuesday stating it's not in flood zone, when can you close this loan? What is the waiting period if it is in the flood zone?
12/07/2009
There was a question: <a href="http://www.bankersonline.com/lending/guru2009/gurus_ldng090709d.html">Timeframe to Provide Flood Insurance</a>, regarding a loan that fell into a flood zone as a result of a mapping change. The guru responded, "You need to send the borrower the Notice of Special Flood Hazard..." I could not find where this was a requirement in FEMA, any ideas? It does not fall under the Make, Renew, Extend or Increase criteria for a flood notice.
11/30/2009
In a recent BOL Flood Q & A webinar, presenters responded to a question asking about when a flood policy should be force placed for missing or incorrect information. The response was that if it was critical information, such as a flood zone discrepancy, one should force place. At the annual conference in Orlando, the presenter from NFIP said that you cannot force place for a flood zone discrepancy. The Q & A covers all of the steps a lender should take regarding zone discrepancies, but does not say to force place. Are we, or are we not, supposed to force place for flood zone discrepancies?
11/23/2009
Relative to the question: <a href="http://www.bankersonline.com/lending/guru2009/gurus_ldng082409e.html">Flood Insurance on Bank Owned Foreclosed Property</a>. what if the bank has not foreclosed, but the property is in nonaccrual/charge off status on the books, security has not been released, the customer is still living in the home, and there are no plans to remove him?
11/23/2009
Is an "All Risk" policy one that covers hazard and flood acceptable for flood insurance?
11/09/2009
In trying to maintain adequate flood insurance coverage, if an existing policy reflects Zone A coverage and the flood determination reflects Zone AE, is the existing policy satisfactory? Also, if the policy reflects Zone AE coverage and our flood determination says Zone A1, do we have satisfactory coverage? In both of these situations, the amount of the flood insurance is satisfactory, I am just questioning whether a difference in the zone is an issue. They are both different versions of Zone A.
10/12/2009
Do the typical consumer loan disclosures (namely the TIL and GFE) apply to loan modifications? If no, then what kind of other disclosures due apply (i.e. flood - is it on the bank to recalculate coverage?).
09/07/2009
What are the requirements when a loan is closed not requiring flood insurance, but the maps have changed and the property is now in a SFHA? What is the time frame for the borrower to have to provide flood insurance?