Refinances & Modifications: Flood Considerations

In most cases, new Truth in Lending disclosures are not required when you modify an existing loan. But, you have to be careful that what you call a modification is not actually a “refinance” under Regulation Z, which does require new disclosures. If we step outside Regulation Z, however, and look at the Flood requirements, it really doesn’t matter if you have a refinance or a modification, because flood will likely always come into play.

Kevin explains more in the video.

Video Highlights:

• A bank must not make, increase, renew, extend (MIRE) without following flood rules.
• This may include a Special Flood Hazard Determination, flood Notice, flood insurance, etc.
• Coverage needs to be recalculated every time there's an MIRE event.

Published
2023/10/22