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An individual applied for a business-purpose loan to be secured by her residence located in a special flood hazard area, and the bank sent a flood notice addressed to the individual. The applicant asked application be modified listing a LLC as the applicant. Must the bank resend the flood notice to reflect the LLC’s name?

An individual applied for a business-purpose loan to be secured by her residence located in a special flood hazard area, and the bank sent a flood notice addressed to the individual. Shortly thereafter, the individual formed a limited liability company (LLC) and asked that the application be modified listing the LLC as the applicant. Must the bank resend the flood notice to reflect the LLC’s name?

Yes. The notice must be provided “to the borrower” (see 12 CFR §22.9(a), §208.25(i) and §339.9(a).) In this case, the borrower is now the LLC. (November 2018)

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