Once a property securing a loan is determined to be in a flood area it's the Banks responsibility to assure flood insurance coverage is maintained throughout the term of the loan. The Interagency Questions and Answers regarding forced placing flood insurance states that one of the circumstances that must occur before the Bank can force place coverage is if coverage is inadequate or does not exist. The NFIP requires 45 days notice to the borrower before coverage can be obtained for the borrower. Does this mean in order to maintain continual coverage that we would have to notify the borrower 45 days prior to their current policy expiring of their need to renew the policy in order to assure that continual coverage is maintained?

Flood Insurance Renewal discussion.