The way we treat it and the way our FDIC examiners have explained it to me, is that you cannot forceplace the insurance to make the loan. On a renewal, if the forceplaced policy was ALREADY in effect, we could close using that policy.
In the situation you are describing, we would deliver the flood notice and the 45-day letter. We would run through the forceplacement process to get a policy on the property, BUT we would delay closing until the borrower produced their own policy.
In your case, you do not already have a forceplaced policy in effect. You have a new MIRE event which requires you to notify the borrower that they need to get flood insurance. They now have a choice to get the policy to close the renewal, pay the loan off, or default on the loan.
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.