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#2115035 - 01/20/17 08:43 PM Force Placed Flood Insurance Notices
Compliance Specialist Offline
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I know that there are three notices that have to be provided to the borrower when a current flood policy is about to expire. Can anyone provide me with a calendar, chart or cheat sheet to know when the letters are to be sent out?

Or

can someone explain. Lets say the flood insurance currently in place is to expire on March 1, 2017 when am I to send the notices to the borrowers?

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Flood Compliance
#2115235 - 01/24/17 02:33 AM Re: Force Placed Flood Insurance Notices Compliance Specialist
David Dickinson Offline
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Central City, NE
There is only 1 notice that is required when force placing insurance. It is to be given as soon as the borrower's policy expires. The MPPP has a series of 3 letters, but this is not required. They were only provided in the (now repealed) Mandatory Purchase of Flood Insurance Guidelines.

In the example you provide, you can notify prior to 3/1/17, but you must notify on 3/2/17. Again, only 1 letter and there's no specific format or requirements to be contained in the notification letter.
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#2115250 - 01/24/17 12:53 PM Re: Force Placed Flood Insurance Notices Compliance Specialist
rlcarey Offline
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Galveston, TX
David - the three letter format is a requirement for participating in the MPPP program and supersedes the regulatory requirements of the prudential regulators as it is more restrictive and is still in effect:

https://www.fema.gov/media-library-data/...ents_2017FY.PDF
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#2115428 - 01/25/17 12:40 AM Re: Force Placed Flood Insurance Notices Compliance Specialist
David Dickinson Offline
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David Dickinson
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Central City, NE
You're right Randy. I should have clarified "the 3 letters are NOT a requirement if you're not force placing a MPPP. If you are force placing an MPPP, then you need to give the 3 letters." Thanks for the clarification.
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#2118225 - 02/14/17 08:29 PM Re: Force Placed Flood Insurance Notices Compliance Specialist
ahkcompliance Offline
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Midwest
When we force place flood insurance, do we need to send a new Flood Notice to the borrower?

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#2118227 - 02/14/17 08:36 PM Re: Force Placed Flood Insurance Notices Compliance Specialist
rlcarey Offline
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rlcarey
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Galveston, TX
The Notice to Borrowers is only required for a MIRE event.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2118240 - 02/14/17 09:16 PM Re: Force Placed Flood Insurance Notices Compliance Specialist
ahkcompliance Offline
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Midwest
Thank you!

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#2119546 - 02/24/17 09:53 PM Re: Force Placed Flood Insurance Notices rlcarey
TeamComply Offline
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So there is no notice requirement when the bank actually force places the flood insurance? We provided the 45 day notice to obtain/provide insurance, but are nearing the end of that period and will likely be force placing the insurance, so I was wondering if there is any required notice (or if it is a common practice to send a notice when we actually force place)? Thanks.

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#2119557 - 02/24/17 10:29 PM Re: Force Placed Flood Insurance Notices Compliance Specialist
TeamComply Offline
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And one additional question...when we do force place can we require the borrower to pay the full premium amount upfront or must we give them the option to add this to their monthly payment amount over the next twelve months?

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#2119565 - 02/24/17 10:59 PM Re: Force Placed Flood Insurance Notices Compliance Specialist
David Dickinson Offline
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David Dickinson
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Central City, NE
So there is no notice requirement when the bank actually force places the flood insurance?
Not from a regulatory standpoint. You might send one from a customer service angle. I'm not aware of any banks that do send another notice. They've already told them they are going to do this.

And one additional question...when we do force place can we require the borrower to pay the full premium amount upfront or must we give them the option to add this to their monthly payment amount over the next twelve months?
This is a contractual and/or customer issue as well. Some banks bill the customer. Some add it to the principal balance. Either way, I recommend you require and set up an escrow for the next year's premiums.
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David Dickinson
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