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#2242377 - 09/14/20 02:18 PM Agent Certification for Acceptance of Private Insu
Cloud9 Offline
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Joined: Jul 2008
Posts: 205
If we were to provide a checklist to the agent to complete and sign indicating whether the policy met the mandatory acceptance guidelines, would we be in compliance? I don't feel comfortable trying to move that responsibility to the insurance agent. We would still be ultimately responsible for the answers to those questions right? Are we required to determine whether the borrower can afford the deductibles for mandatory acceptance?

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Flood Compliance
#2242378 - 09/14/20 02:30 PM Re: Agent Certification for Acceptance of Private Insu Cloud9
rlcarey Online
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Joined: Jul 2001
Posts: 79,293
Galveston, TX
You are still on the hook for compliance. Acceptable deductibles, as long as they are in line with what is available under the NFIP is purely a safety and soundness issue - although there would be fair lending consideration is you were not consistent.

The regulations read: bank documents its conclusion regarding sufficiency of the protection of the loan in writing.

That does not say agent.
The opinions expressed here should not be construed to be those of my employer:

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