I would like to get your thoughts on a situation involving flood insurance requirements. Please let me know if you need any additional details in order to assess.
Residential mortgage
Property mapped in to a flood zone 6/2019
Borrower notified flood insurance required
Borrower provides Private Policy with coverage effective 8/31/2019 – 8/31/2020
Borrower works with a surveyor to add fill to his property in effort to obtain LOMA
LOMR-F dated 3/24/2020 removes property from flood zone
Private insurer cancels entire policy, back to 8/31/2019
Is lender required to maintain flood insurance coverage (i.e., force place) between 8/31/2020 – 3/24/2020?
NFIP Flood Insurance Manual seems to potentially support cancellation of the policy back to the effective date of the policy.