What dates are they putting on those forceplaced policies? What type of policies are they (MPPP, private, etc)?
The 3 letter requirement at day 1, day 30, and day 45 is only required on MPPP policies (and the 30 day letter is optional). On private policies, you only have to send the day 1 letter to start your process. So depending on what type of policies your vendor is forceplacing with, you may or may not have an issue with your letters.
You need to have a forceplaced policy in place by day 46 after the initial letter goes out regardless of the type of policies you are forceplacing.
As far as your vendor never being criticized, well, they wouldn't be the ones who are criticized....the banks are the ones who are criticized. So technically they are telling the truth. However, it doesn't matter. Just because they haven't been criticized doesn't mean that they aren't violating the flood rules. It just means no one has told them....yet.
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.