Here's a good article on the change to detached structures:

http://www.jackscomplianceresource.com/affordability-act-controversy-on-detached-structures/

Check the last section on What is Not so Clear...we are waiting for additional guidance based on the same reasons.

Looking for some clarification - If we have propeties that will be underinsured effective 6/1/14, do we send the letters out now, or do we have to wait until 6/1 to send the letters. We have knowledge that we know effective 6/1 they are underinsured, so I think we would send it now.

Anyone weigh in?

I'm also looking for clarification, what changes will you be making to your flood policies to include the new requirements?

You are required to take action (send the 45 day letter) when you know they are either not insured or underinsured. You cannot know that until June 1 when that date gets here and you do not have a new declaration page in your hand.

However, that is not to say that a bank might not want to call on these specific customers ahead of time and sit down and explain the situation.

Just sending a 45 day letter to a customer in this situation on June 1 without other communication is sure to both cause confusion and [censored] them off.

I agree with rlcarey. Call the customers and advise them of the changes. They should have received a letter from their insurer, but some, if not most, customers probably did not read it or understand the ramifications completely.

Keep in mind that change endorsements have a 30-day waiting period, so you want your customers to initiate this asap.

45 day letters on June 1.

Thanks for the clarification