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#2219203 - 08/06/19 06:43 PM Private Flood Insurance Policy Declaration Page
City Girl Offline
100 Club
Joined: Sep 2005
Posts: 159
Midwest
I found they verbatim statement on the bottom of the declaration page. Is this good enough to be compliant or do I need to review the policy for the verbatim statement?

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Flood Compliance
#2219506 - 08/12/19 12:30 PM Re: Private Flood Insurance Policy Declaration Page City Girl
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,662
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.”"

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/definitions

The 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.
Last edited by Adam Witmer; 08/12/19 01:17 PM. Reason: Further clarification
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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.
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#2219583 - 08/12/19 09:43 PM Re: Private Flood Insurance Policy Declaration Page City Girl
Kimo in Idaho Offline
100 Club
Joined: Jun 2019
Posts: 135
Thanks Adam! your insight is greatly appreciated!

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#2238926 - 07/01/20 08:26 PM Re: Private Flood Insurance Policy Declaration Page City Girl
scb2011 Offline
Gold Star
Joined: Mar 2011
Posts: 258
TN
Does anyone have any updated information related to the compliance aid statement appearing on the declarations page? I have this situation today, and am wondering if anyone has seen a clarification as to whether that is acceptable?

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#2238958 - 07/02/20 02:07 PM Re: Private Flood Insurance Policy Declaration Page City Girl
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Not that I am aware - it was not even addressed in the new proposed Flood Q&As that came out last week.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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