August 8, 2019 at 4:31 pm #15942
We listened to a webinar yesterday and the presenter noted that if we force place flood insurance that the borrower cannot replace the force placed insurance with a private flood insurance policy. Is this true? And if so, can you provide the site?August 13, 2019 at 4:35 pm #15951
This wasn’t one of our webinars/recordings, correct?
I’m not sure exactly how the presenter stated this, but you can accept a private policy in place of a force place policy if it meets the criteria. Perhaps what this presenter was talking about was the extra work/potential confusion for your staff because often times borrowers only bring you a dec sheet for review, which was acceptable under the previous rules. Review of a dec sheet may not be sufficient for private policies and you would need to conduct the same review as you would if there was not a force placed policy in place.
From p. 20-21 of the final rule:
One commenter was unsure how the mandatory acceptance requirement would affect preexisting force placement requirements
28 that provide for the release of a force placed policy following the presentation of a declarations page by the borrower evidencing the borrower’s purchase of flood insurance. Another commenter asked whether regulated lending institutions are expected to force place insurance if the full policy is not available.
The Agencies acknowledge that under existing force placement requirements, a declarations page is sufficient to evidence a borrower’s purchase of flood insurance. However, a declarations page may be insufficient for a regulated lending institution to make a determination that the institution must accept a private flood insurance policy in satisfaction of the flood insurance purchase requirement if the declarations page does not provide enough information for the institution to determine that the policy meets the statutory definition of “private flood insurance.” In these circumstances, the regulated lending institution should request additional information about the policy to aid it in making its determination.
August 14, 2019 at 12:23 pm #15960
- This reply was modified 3 days, 9 hours ago by rcooper. Reason: typos
This was not a webinar/seminar that was put on by Jack. The webinar was provided by our Core Provider. The presenter may have just gotten confused or misstated something.
Thank you for your help!!!August 15, 2019 at 9:54 am #15964
No problem. Glad we could help!
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