FDIC Federal Register Citations

From: Don Copeland
Sent: Friday, March 28, 2008 5:06 PM
To: Comments
Subject: Joint Notice - Flood Insurance - RIN 3064-ZA00

Question 3 discusses whether any requirements under the Regulation are triggered when a lender’s purchase of a loan from another lender, secured by a building or mobile home located in an SFHA in which flood insurance is available under the Act.  I would like to see the Answer expanded to discuss a situation that is closely akin to the foregoing, that situation being when a borrower assigns a promissory note and real estate mortgage to secure a loan.  Whereas the latter approach causes the person to be liable, potentially the person could have sold the loan and mortgage to the bank.  Essentially, there is little difference in a loan purchase and the taking of an Assignment of Promissory Note and Assignment of Real Estate Mortgage.

It doesn’t seem that providing such relief would create a significant loophole for the purpose of escaping flood insurance.

Thank you for your consideration. 

Don Copeland
Loan Compliance