Thoughts on allowing HELOC advances during the force placement process? We started the force placement process and I'm wondering if we should be allowing the borrower to continue to advance on the HELOC during this time. The advances would not be to pay for flood insurance if that matters. Thank you.

I would:

1026.40(f)(3)(vi) Prohibit additional extensions of credit or reduce the credit limit applicable to an agreement during any period in which:

(C) The consumer is in default of any material obligation under the agreement;

Thank you. For the sake of updating procedures, would it be the same for newly mapped flood properties (or newly identified) where we are doing the initial notification? Would it be safe to say we should prohibit advances anytime a 45 day letter is sent? Or are they technically not in default since they just found out about the requirement?

I would not press the issue if they were just mapped into the area. The customers that have let their flood insurance lapse however, I have absolutely no sympathy for....

And again, this is bank policy decision and not a regulatory one.