I am wondering what sort of actions can be taken if we provide the 45-day notice, and then the borrower provides evidence of new insurance, but there’s still a lapse between when the old policy ended and the new one began. For example, in a situation where an old policy expired on March 1 and the new policy started on March 10, we know that we need to send another notice, but when can we charge the borrower for the ten days without insurance? At the end of the initial 45 days or fifteen days after providing the second notice?

Did you force place on day one? You are allowed to charge them for the period of time in which they did not have flood insurance and the force placed policy was in place on day 46. Without force placing on day 1 - what would you charge them for?

Yes, we forced-placed on day 1 and sent the 45 day notice. Before the 45 day notice period was up the borrower brought in proof of insurance; however, it showed a lapse of 10 days coverage.

So... since we received the proof of insurance do we have to wait till the end of the 45 day period before charging the borrower for the 10 days of lapsed coverage or can we do it right away?

Thank you

I don't think it is addressed anywhere, I would think you could just charge them and be done with it. Whether you wait until day 46 has no impact on the facts at hand. There is nothing more that the borrower can do.

Randy, thank you!