We had an unfortunate incident occur recently. After we had already closed a mortgage loan it was noticed that the Flood Cert had the incorrect address. (It is part of the UW process to review this but unfortunately this was missed.) A new flood cert was obtained and the property came back in the flood zone. Unfortunately we closed our loan without having obtained a Flood Hazard notice and without obtaining flood insurance. Do you have any guidance on how we should handle this situation? I am thinking we should have the notice signed by the borrower and require them to obtain the flood insurance coverage. Should we also provide a corrected CD and escrow notice disclosing the escrow for flood ins?
This is unfortunate. You have violations. There is no cure for the failure to obtain flood insurance, but your suggested actions are the best course of action. The actions result in flood insurance for the loan and the consumer receiving correct disclosures.