Can I add on to this post by asking about FP flood policy renewals? I know that if an institution participates in the MPPP program that they can provide the 45 day notice PRIOR to expiration of the existing FP policy. But what if an institution does not participate in the MPPP program? It was always my understanding that the 45 day notice should not be sent until expiration or lapse of the existing policy, including the renewal of an existing FP flood policy.

What should the practice be, and are there institutions that send the 45 day notice prior to the expiration date on renewals?

The mandatory letter ("45-day letter") should go out at expiration; "before" is only allowed in association with MPPP policies.

That said, the Agencies' commentary in federal register supports the practice of sending pre-expiration/pre-renewal notices in addition to sending the mandated letter once coverage expires.

I agree that you can advise borrowers to renew their insurance prior to the expiration. This isn't the "45 day letter" or any type of force placement requirement. It's a "heads up" practice that some institutions utilize. So when you ask "What should the practice be" it's voluntary to send anything prior to expiration and it's up to you institution.