Thoughts please:

Is there a UDAAP concern for not informing the borrower of their FP flood policy coverage?
If the regulation states that force placed coverage should be obtained for the benefit of the borrower, and the borrower is being charged; shouldn't they be made aware of the amount of coverage.

Example: Borrower is informed of their coverage amount at initial placement of the FP policy. Then at annual renewal a renewal notice is delivered that includes the renewal premium, but does not include the coverage amount. The coverage amount sometimes changes at renewal if the loan is paid down; so it could be different than what was originally placed.

I would love to hear other's opinion on this since UDAAP is rather subjective.

Since you are placing it on their behalf, they must be a named insured and therefor they should be getting a copy of the declaration page and a copy of the policy so they know what is covered and how to file a claim.

They would receive that information from the insurance company or the servicer, correct?

You would have to read your contract with the insurance company or servicer to figure out who was responsible for what in a force placed environment. I would not be doing much assuming of anything. Why would you not get a copy of at least the declaration page for your borrower files for use in case of a borrower dispute?