At this point, I have not seen any guidance regarding the compliance aid being listed on a declaration page. The challenge is that the final rule says that the aid must be either included on the policy or included as as an endorsement to the policy. I specifically submitted a question for the interagency webinar on private flood insurance about whether the compliance aid listed on a dec page would be sufficient and all they said was this:
"A declarations page would not provide enough information for the mandatory acceptance rules or for the institution to determine that the policy meets the statutory definition of “private flood insurance.â€"While that statement seems to imply you can't rely on a compliance aid on the dec page, FEMA's definition of a dec page does say that a dec page is part of the policy.
"The declarations page is a part of the flood insurance policy." https://www.fema.gov/national-flood-insurance-program/definitionsThe bottom line is that I don't think the answer is abundantly clear, so it is up to you to decide if you are comfortable with the compliance aid on the dec page without further reviewing the full policy.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com