Borrower provided the bank with a private flood insurance policy several months ago. The flood policy provided adequate coverage as well as the following wording" This policy meets the definition of private flood insurance contained in 42 U.S.C. 4012a (b) (7) and the corresponding regulation".

The flood policy expired on 10/17/2021 and we provided the proper notices as required. We do not force place on day one. The borrower provided the bank a renewal policy that was effective 10/25/ 2021, eight days after the original expiration.

Since this is a private flood policy and there was a gap of coverage for eight days would this be considered a violation of the regulations?

Generally policies will have a grace period (NFIP policies - 30 days) before coverage lapses. Did you check the policy?

Yes. I went over the policy line by line and did not see a grace period listed.

I am not sure why you would treat a private policy any different than a NFIP policy, but that represents a significant safety and soundness gap.