I'm confused by a statement on Page 13 referencing forced-place provisions. It states in item (iv):

"amends the force-placement requirement to clarify that regulated lending institutions may charge a borrower for the cost of premiums and fees incurred for coverage beginning on the date on which the flood insurance coverage lapsed or did not provide sufficient coverage and to prescribe the procedures for terminating force-placed insurance. 16"

Next paragraph:
"The civil money penalty provisions, 17 and the force-placement requirements were effective upon enactment."

Really? I thought it was only the procedures for terminating force-placed insurance. But this sounds like it included the first part as well.

Help me, David.

Ann,

Here is one thread where this was discussed earlier this year: Interagency guidance issued on Biggert Waters...but.

And here is the guidance issued by the FDIC around the same time: FIL-14-2013. Under the Force Placement section of this FIL, it states: "It is the Agencies’ position that the force placement provisions of the Act described above became effective upon enactment."

MarkB