Good Morning...is it allowable, per the regulation, to accept a property policy that includes flood coverage ?

Thanks for your help!!

Sure if it meets the new private policy requirements. It used to be not uncommon for flood insurance to be included in the hazard insurance on mobile homes in the past in some jurisdictions. Most of those policies would have met the new requirements, but the policy would have to be examined under the new regulatory requirements.

What do you mean by a "property policy"?

The regulation requires improved property located within a SFHA to have "adequate coverage." If what you are asking is "can this be completed by a hazard insurance policy that also covers flood insurance?", then yes. Accord Mobile Home policies are a good example of this. However, be sure to dig deep and ensure the flood insurance meets all of the requirements of the Flood Insurance Act.

This is tricky as I don’t speak insurance agent; when they sent me the acord cert., I asked if it was dedicated flood policy and they said it’s a property policy with additional flood coverage through Travelers....those were her exact words. My comfort zone is NFIP policies, so I’m not sure what I should be looking at. Also, it’s only a cert., as it’s a new policy and we won’t get the declaration page for a few weeks. It’s a commercial building, the coverage looks good, but the accord cert. didn’t include the compliance aid statement…so I don’t know whether to accept it. To make matter worse, time is off the essence, as this borrower waited too long, and we are scheduled to forced place tomorrow, oy.

Thanks for the replies, its appreciated!

I would force place and review the policy for acceptability when it is received. If it is acceptable when received, then you can retro cancel the force placed policy. This is the borrower's fault and not the bank's from your description.

Where can I find the standard requirements that meet the definition of private flood insurance if there is no assurance statement in the policy?

208.25(b)(9)

https://www.bankersonline.com/regulations/12-208-025