Due to FEMA map revision, when now have lots of customers now requiring Flood Insurance. Using the MPPP letters, we sent out our first round of notices. All the notices appear to suggest that the customer has 45 days to get the insurance in place, if not, the bank will force place on the 46 day.

When exactly should we force place the insurance to be in compliance? If we intend to force place sooner than day 46, shouldn't we revise the MPPP letters so the customer is informed of our intentions. It just seems a little deceptive to me when telling customers they have 45 days to purchase the insurance and then force placing the insurance prior to the 45 period.

When exactly should we force place the insurance to be in compliance?

No later than the first business day after day 45.


You can force place on day 1 if you want, you just cannot charge the borrower any premiums for the 1st 45 days.