Sorry guys...I know this subject is getting old...

We are using RCV listed on our appraisals when determining the amount of coverage needed on all of our originations. Currently we are working on a portfolio audit to make sure we have adequate coverage on some of our loans that have been on the books for several years. What is the opinion of the group as to which RCV to use when making this determination? RCV on the most recent appraisal (which could be up to 10 years old) or is it acceptable to use the RCV listed by the insurance agent? We have to keep in mind the investor loans and the 80% that comes into play on these. If the RCV on the appraisal is showing $95,000 but the insurance agent is showing RCV at $140,000, should we use the insurance agents opinion?

From page 28 of the Mandatory Purchase Guidelines:

Lenders should seek the assistance of property insurance agents or companies when determining the appropriate flood insurance coverage amounts, as they do for other lines of insurance. . . . .

However, in these situation I would hope the current loan balance would be the lesser of the required coverage amount. Especially on a 10 year old loan.