We have an issue that I am trying to figure out. We have blanket policy which covers 6 residential condo units or which our subject property is a part of. It is assumed at this point that it is a private flood policy. All the insurance company has furnished to the Bank is the evidence of insurance which has sufficient coverage. The insurance company we are dealing with, the broker, advised us they cannot send the policy as they have still yet to receive it from the insurance provider. I advised them that we need a copy of the policy or just the endorsement permitted under the new rule, or a copy of the RCBAP declaration page if the policy is actually not private, or else we will need to begin the force placement process.

Has anyone else had this issue? Any one have best practice suggestions to avoid this? Unfortunately this file was pulled as part of an examination? Any idea how the examiner will react?

Has this policy renewed yet under the new guidelines??

But you are asking the correct questions. How did this loan close originally? You had to have something more than that at that time.

The flood portion of the flood policy renewed recently, early January I believe. I do not know how long the loan has been on the books or what they originally received at time of origination. All we have now is a copy of the Evidence of Insurance which if it is a private policy would not be sufficient. From the lack of response from the insurance broker, I do not feel like it is a high priority on their list, meanwhile the examiner is questioning why it is taking so long to get them their request.

Prior to accepting a private policy at the time of the renewal of the flood policy and after the new regulation became effective, you had to determine whether or not the private policy was acceptable.

You are not in a good position.

Yes, that is what I was afraid of.

Update: I explained the situation to the examiner and he as of right now he is OK. He understands that we are doing everything in our power to comply. Luckily he is using common sense. The borrower and unit are fully covered, the deductible is at the max, and the only things we are not able to ascertain from the EOI is the cancellation policy, year requirement to submit a claim etc, which has nothing to do with our borrower as he is not the direct insured, the Condo Association is, so he would not be able to cancel the policy or file a claim directly. Also he sees no reason in starting up the force placement process as if we end up force placing it will only harm the borrower as they would be required to pay the bill without the benefits of the insurance because only 1 policy will payout.
I am lucky to have him as our EIC. He stated he will look into what the Bank can do in this situation which may require us to start the force placement process but he will let us know and that we should keep on documenting our efforts to obtain the policy.