Hello:

If we received a communication from our flood vendor about a map revision showing a property that is now in a flood zone, do we need to send the 45 day letter if the client already had a flood insurance policy in place with the bank as the mortgagee and we had a copy of it in his file already?

The borrower always had carried flood insurance even though at the time of our loan transaction long ago he was not mapped into a flood zone.

I have not had an occurance where I have received the communicaiton change and have already had flood insurance in place by the borrower.

Please advise. Thank you.

You still need to ensure the policy is for a SFHA. He could have had a policy for a B zone which is not considered a SFHA. The notice that they are in a SFHA and that flood insurance is required, despite them having the prior policy, should still be provided. That is simply a due diligence process you should have consistent in your processes and procedures for MIRE, regardless if they had it prior to you requiring it.

Yes, we did have them sign the notice but I am wondering if I need to show proof of a 45 day letter in the file?

Did their policy lapse?

The "45 day letter" is a Force Placement notification. You use it to notify them they don't have adequate insurance. If they do have adequate insurance, no force placement procedures are necessary.

No the policy did not lapse and is still effective when we were notified of the map change to put them into a flood plain. Thank you for everyone's responses. I really appreciate it. I didn't think I needed to provide the 45 day letter, but have never run across this before so did not want to assume. Ha!