Absent the MIRE Event issue, is it a violation of the regulation to do the following on a closed-end consumer loan:
Unpaid Balance $200,000
Force Placed Insurance Amt. $3,250
Force Place Policy written for $203,250
Appraised Value $270,000
Auditors are reading the regulation to say the force place amount must be the lesser of the unpaid principal balance or the maximum amount of NFIP, whichever is less.
I read it to say the amount must at least be the lesser of the unpaid principal balance or the maximum amount of NFIP. in this case, it more than the unpaid principal balance, but does not exceed the nfip maximum of $250,000. appreciate your thoughts.