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#2262691 - 11/18/21 10:54 PM private flood insurance policy
parr04 Offline
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Joined: Aug 2004
Posts: 391
oklahoma
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?

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Flood Compliance
#2262700 - 11/19/21 02:44 PM Re: private flood insurance policy parr04
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,030
Bloomington, IN
Generally policies will have a grace period (NFIP policies - 30 days) before coverage lapses. Did you check the policy?
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#2262751 - 11/19/21 11:02 PM Re: private flood insurance policy Dan Persfull
parr04 Offline
Gold Star
Joined: Aug 2004
Posts: 391
oklahoma
Yes. I went over the policy line by line and did not see a grace period listed.

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#2262765 - 11/20/21 08:53 AM Re: private flood insurance policy parr04
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 80,393
Galveston, TX
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.
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