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From: Don Copeland
Question 3 discusses whether any requirements under the Regulation are triggered when a lenders 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 doesnt seem that providing such relief would create a significant loophole for the purpose of escaping flood insurance.
Thank you for your consideration.
|Last Updated 03/31/2008||Regs@fdic.gov|