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#1637519 - 12/09/11 06:02 PM 45 day notification for FP
CMLComp Offline
Member
Joined: Dec 2011
Posts: 90
Guidelines indicate borrower must provide insurance within 45 days of first notification, should coverage be placed on day 45 or day 46?

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Flood Compliance
#1637607 - 12/09/11 07:23 PM Re: 45 day notification for FP CMLComp
AFaquir Offline
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AFaquir
Joined: Jan 2011
Posts: 763
Top of the world... and never ...
pretty sure day 45.
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#1637613 - 12/09/11 07:28 PM Re: 45 day notification for FP CMLComp
WI Banker Offline
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Joined: Dec 2006
Posts: 253
The borrower gets the full 45 days to get their own insurance, so don't force place until the 46th day.

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#1637670 - 12/09/11 08:58 PM Re: 45 day notification for FP WI Banker
Tillie Offline
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Tillie
Joined: Apr 2003
Posts: 266
We mailed first notificattion to borrower on 9-23 with the required notice. The effective date on the policy the borrower purchased is 11-8. That's day 46. So according to what I am reading here, we don't do anything about force placing a policy since our policy should be dated 11-8, the 46th day.
Is that right?

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#1637679 - 12/09/11 09:07 PM Re: 45 day notification for FP Tillie
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,292
Review question 61 of the interagency q and a issued in 2011. In the discussion section of the issuance, the agencies state:

"The Agencies received comments from six commenters addressing proposed question and answer 61. Two lender commenters explained that batch processing of force placed flood insurance policies may cause a brief delay in the completion of the force placement process. They requested that the Agencies specify in the answer that, if a policy is in effect, for example, five days after the end of the 45-day notice period, then the force placement time frame has been satisfied. The Agencies decline to set an arbitrary number of days after the end of the 45-day notice period as a “safe harbor” for completion of the force placement process. The Agencies believe that the lender should
have policies and procedures in place to allow force placement generally to commence when the 45-day notice period has expired. However, the Agencies also recognize that the process of force placing flood insurance may not always occur immediately on the 46th day. If there is a brief delay in force placing the required insurance, the lender should be able to provide a reasonable explanation for the delay. "

Some banks or their vendors process force placement once a week or a similar time period. The insurance is often effective as of the proper day, however.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
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#1637680 - 12/09/11 09:07 PM Re: 45 day notification for FP Tillie
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
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"The effective date on the policy the borrower purchased is 11-8."

Do you mean that their policy expires on 11-8?
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#1637738 - 12/09/11 11:07 PM Re: 45 day notification for FP manimal
Tillie Offline
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Tillie
Joined: Apr 2003
Posts: 266
The policy is effective from 11-8-11 to 11-8-12.
I think we can reasonably explain to examiners why we didn't force place a policy.

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#1637741 - 12/09/11 11:19 PM Re: 45 day notification for FP Tillie
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,292
You have insurance as of day 46. You are fine.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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