Our current practice is to run flood during the processing of an application, after the early disclosures have been provided. Post effective date of TRID and following the same practice, I believe that upon determining that a property requires flood insurance coverage would be a change in circumstances and the premium for the insurance would be disclosed in a revised disclosure? If that is true, would the fact that the bank had the ability to determine the flood status as soon as it received the application, but elected to do so later, be viewed as failing to provided the Loan Estimate in “Good Faith”?
I agree that once you determine flood insurance is required you have a changed circumstance and would follow the rules for a revised loan estimates under 1026.19(e)(3)(iv). I don’t believe determining a loan is in a flood zone (and requires flood insurance) after issuing the LE would be considered not acting in good faith.