We have been looking for the timing requirements to send the initial force-place letter to a customer when the existing policy expires. I've looked through several sources (Federal Reserve being one since we are a Fed bank) and can't find a definite answer.

Can anyone guide me?

Thanks!

As soon a reasonably practical. Like the day after

Actually, it depends on your procedure. If there is business day or two delay, that is probably acceptable. If you are not doing it for a week, that might not be deemed reasonable. Most just have a tickler set for the day of expiration, produce the letter and drop in the mail the next day unless a policy showed up.

I'm reading the Federal Register published on 7/21/15, and it says "the final rule clarifies that the required 45-day notice must be sent following the date of lapse or insufficient coverage of the borrower's policy". The same final rule outlines that the agencies consider the policy to have lapsed as of the expiration/cancellation date of the policy.

So, based on this, does this mean the 45-day letter should be sent on the date of expiration/cancellation of the policy, or on the day after the expiration/cancellation of the policy?

Flood policies expire at 12:01AM on the expiration date.

If that's the case, then it would seem we should send it on the date of expiration?

I don't think the regulators are going to care as long as it gets out in a business day or two. At least not in my experience. Tickle the file for the expiration date, then draft your letters and mail. Just establish your process and follow-thru with it.