Voluntary escrow accounts requested by the borrower do not trigger the requirement that the lender escrow flood insurance premiums. Interagency Questions and Answers Regarding Flood Insurance, 62 Fed. Reg. 39523, 39527. The flood regulations require the escrow of flood insurance premiums only if the lender “requires the escrow of taxes, insurance premiums, fees, or any other charges for a loan secured by residential improved real estate or a mobile home.” 12 CFR 339.5. If you do not require the escrow of any of those items, you are not required to escrow flood insurance (though you do have to ensure that the property is covered by flood insurance).