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#2236126 - 05/04/20 08:23 PM Proof of Insurance - Private Policy Renewal
Likes to Comply Offline
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Joined: Nov 2008
Posts: 1,054
In the mountains
What is acceptable proof of renewal of a private insurance policy? Must whatever that proof is (such as a renewal notice) also provide the "This policy meets the definition of provide flood insurance contained in 42 U.S.C. 4012a(b)(7) and the corresponding regulation" notice?
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Flood Compliance
#2236156 - 05/05/20 01:13 PM Re: Proof of Insurance - Private Policy Renewal Likes to Comply
Jerod Moyer Offline
Platinum Poster
Jerod Moyer
Joined: Oct 2005
Posts: 667
Sioux Falls, SD
The following is from the final rule on evidence of Private Flood Insurance coverage. IMO the renewal information either needs the disclaimer you quote or you'll have to manually review the policy to determine if the private flood criteria is included. There's discretionary criteria is also in play.

The Agencies acknowledge that under existing… requirements, a declarations page is sufficient to evidence a borrower’s purchase of flood insurance. However, a declarations page may be insufficient for a regulated lending institution to make a determination that the institution must accept a private flood insurance policy in satisfaction of the flood insurance purchase requirement if the declarations page does not provide enough information for the institution to determine that the policy meets the statutory definition of “private flood insurance.” In these circumstances, the regulated lending institution should request additional information about the policy to aid it in making its determination. [Final Rule Overview – January 25, 2019]
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Jerod Moyer
www.bankerscompliance.com

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