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#1099649 - 12/18/08 06:04 PM Flood Insurance Review
Forest Critter Offline
Junior Member
Forest Critter
Joined: Aug 2007
Posts: 40
Oregon
I am doing a review of all loans, commercial and mortgage that have flood insurance that funded in 2008.

Several issues have come up that I thought I would post here:

1. I have noticed a few flood policies that are written by a WYO contracted insurance company but the policy is not
a standard NFIP policy, or the policy was written by a non-NFIP company. Does anyone have a checklist or tool for reviewing Non-NFIP policies? Why would a WYO company promote and sell Non NFIP policies?

2. Which department in an organization is typically responsible for ensuring flood insurance is in place prior to funding? We have power struggles about who should be responsible. Underwriting? Compliance Dept? Loan Officer?

3. We have a loan where a elevation cert was submitted to the insurance company who accepted it as evidence and subsequently insured to a lower rate and flood zone. The elevation cert was never submitted to FEMA.

Do you think we will ever have a "Flood Insurance" forum here at BOL?

Thanks for your comments!

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Lending Compliance
#1099655 - 12/18/08 06:13 PM Re: Flood Insurance Review Forest Critter
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
What must be in the policy can be found in the Flood Guidelines.

Find out what works best for your office. Our LO's are utlitmately responsible, but our loan platform area is the bulldog.

About a Flood forum...I was thinking earlier today one could just about be justified!
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1099807 - 12/18/08 08:15 PM Re: Flood Insurance Review RR Joker
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Quote:
3. We have a loan where a elevation cert was submitted to the insurance company who accepted it as evidence and subsequently insured to a lower rate and flood zone. The elevation cert was never submitted to FEMA.

Do they still have it written in a Zone A or V? If not, only FEMA can remove a property from a SFHA. Until a LOMA or LOMR is issued, the borrower must purchase the "correct" flood insurance (what your SFHDF shows). If they don't have it now, you'll need to notify and force place in 45 days.
_________________________
David Dickinson
http://www.bankerscompliance.com

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