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August 6
Part I
Flood Insurance: Requirements and Best Practices
A Two-Part Companion Webinar Series;
David Dickinson and Jerod Moyer

August 12
A to Z of Reg E;
Andy Zavoina

August 13
Part II
Flood Insurance: Requirements and Best Practices
A Two-Part Companion Webinar Series;
David Dickinson and Jerod Moyer

August 14
Advanced Business Accounts - Complicated Issues and Simple Solutions;
Deborah Crawford

August 19
HMDA - Coming Attractions;
Jack Holzknecht

August 20
Safe Deposit Regulatory Compliance & Legal Issues;
Dave McGuinn



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

Registered: 02/06/04
Posts: 1051
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 Online
Power Poster

Registered: 10/01/09
Posts: 3334
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 Online
Platinum Poster

Registered: 07/22/05
Posts: 577
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: 49449
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 Online
Platinum Poster

Registered: 07/22/05
Posts: 577
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: 49449
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 Online
Platinum Poster

Registered: 07/22/05
Posts: 577
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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