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September 8
Checkup for your RDC Program;
Susan Orr

September 10
Critical Issues on Certificates of Deposit;
Deborah Crawford

September 16
S.A.F.E. Act - Auditing for Compliance;
Patricia Cashman

September 22
FinCEN's Beneficial Owners Proposal: What It Can Mean for You;
Sonja Kriegsmann and John Burnett

September 23
Bankruptcy 101;
Sam Ott

September 24
Using CPTED to Make Our Banks Safer;
Dana Turner and Carol Dodgen



Topic Options
#1296669 - 12/01/09 05:11 PM Non-NFIP Policy
Busy Bee, CRCM Offline
Diamond Poster

Registered: 02/06/04
Posts: 1052
Loc: PacificNW
I need some quick flood help, please!

Is it acceptable to have a flood policy that is from a private carrier and not the NFIP? I believe it is, but needed confirmation before I go back to the person that posed the question.

Thanks!

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Lending Compliance
#1296689 - 12/01/09 05:23 PM Re: Non-NFIP Policy [Re: Busy Bee, CRCM]
Doug Hendrickson Offline
Power Poster

Registered: 10/01/09
Posts: 3361
Loc: NE New Mexico
I recall a Q&A in one of my readings that stated that it MAY be an adequate substitute for NFIP insurance if it meets the criteria set forth by FEMA. I think there is a guidelines publication for flood insurance that you need to consult.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1296875 - 12/02/09 10:03 AM Re: Non-NFIP Policy [Re: Doug Hendrickson]
Carolina Blue Offline
Platinum Poster

Registered: 07/22/05
Posts: 591
Loc: Lost in a regulatory fog
Correct. The requirements for the private policy are on page 58 of the FEMA Mandatory Purchase Guidelines booklet.

I do have a quick question about these requirements though. Requirement c. states the policy must give the insurer 45 days written notice of cancellation or non-renewal and that the notice must be sent to the insured and the lender. However, I don't see those requirements anywhere in the SFIP. Am I missing something?

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#1296913 - 12/02/09 10:24 AM Re: Non-NFIP Policy [Re: Carolina Blue]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 49740
Loc: Galveston, TX
It is standard practice on NFIP policies. From the Flood Insurance Manual:

If we decide to cancel or not renew this policy, it will
continue in effect for the benefit of the mortgagee only for
30 days after we notify the mortgagee of the cancellation
or nonrenewal.
_________________________
The opinions expressed are my own, take them or leave them.

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#1297466 - 12/02/09 03:41 PM Re: Non-NFIP Policy [Re: rlcarey]
Carolina Blue Offline
Platinum Poster

Registered: 07/22/05
Posts: 591
Loc: Lost in a regulatory fog
Thanks Randy. So now the question is..
why does the page 58 criteria state the "private flood insurance policy should include a requirement to give 45 days' written notice of cancellation or non-renewal," if the "force place" notification cannot be given until the date of cancellation/non-renewal and we have to wait 45 days anyway?

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#1297486 - 12/02/09 03:51 PM Re: Non-NFIP Policy [Re: Carolina Blue]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 49740
Loc: Galveston, TX
You are asking me for an explanation of FEMA rules - You're kidding - right? smile
_________________________
The opinions expressed are my own, take them or leave them.

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#1297519 - 12/02/09 04:20 PM Re: Non-NFIP Policy [Re: rlcarey]
Carolina Blue Offline
Platinum Poster

Registered: 07/22/05
Posts: 591
Loc: Lost in a regulatory fog
You'd think I've learned by now to remove all logic and common sense from my work life laugh

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