This is concerning the notice we are required to send to the customer once we are aware their flood insurance has expired.

Is it required that the notice has to contain a statement that if the borrower does not purchase the required insurance within 45 days that the institution is required to purchase insurance on behalf of the borrower?

We have chosen to purchase on day 1 and we are afraid this statement would lead the customer to believe that we are waiting until after the 45 day.

Thanks in advance for your help.

Here's the FDIC version of the regulation:

§ 339.7 Force placement of flood insurance.
(a) Notice and purchase of coverage. If an FDIC-supervised institution, or a servicer acting on its behalf, determines at any time during the term of a designated loan, that the building or mobile home and any personal property securing the designated loan is not covered by flood insurance or is covered by flood insurance in an amount less than the amount required under
§ 339.3, then the FDIC-supervised institution or its servicer shall notify the borrower that the borrower should obtain flood insurance, at the borrower’s expense, in an amount at least equal to the amount required under § 339.3, for the remaining term of the loan. If the borrower fails to obtain flood insurance within 45 days after notification, then the FDIC-supervised institution or its servicer shall purchase insurance on the borrower’s behalf. The FDIC-supervised institution or its servicer may charge the borrower for the cost of premiums and fees incurred in purchasing the insurance, including premiums or fees incurred for coverage beginning on the date on which flood insurance coverage lapsed or did not provide a sufficient coverage amount.

(b) Termination of force-placed insurance. (1) Termination and refund. Within 30 days of receipt by an FDIC-supervised institution, or a servicer acting on its behalf, of a confirmation of a borrower’s existing flood insurance coverage, the FDIC-supervised institution or its servicer shall:

(A) Notify the insurance provider to terminate any insurance purchased by the FDIC- supervised institution or its servicer under paragraph (a) of this section; and

(B) Refund to the borrower all premiums paid by the borrower for any insurance purchased by the FDIC-supervised institution or its servicer under paragraph (a) of this section during any period during which the borrower’s flood insurance coverage and the insurance coverage purchased by the FDIC-supervised institution or its servicer were each in effect, and any related fees charged to the borrower with respect to the insurance purchased by the FDIC- supervised institution or its servicer during such period.

(2) Sufficiency of demonstration. For purposes of confirming a borrower’s existing flood insurance coverage under paragraph (b) of this section, an FDIC-supervised institution or its servicer shall accept from the borrower an insurance policy declarations page that includes the existing flood insurance policy number and the identity of, and contact information for, the insurance company or agent.

There is no regulatory required model notice, so there's no required statement.

You can certainly purchase on day 1 and you can charge the borrower from day 1. If you do, you must reimburse the borrower for any double coverage within 30 days of determining they have purchase their own insurance.