Currently we buy Forced Placed insurance on day 46 and back date the insurance to the date of expiration, is this practice acceptable and not considered backing which is referenced in Q & 9 of the new Interagency Q & A for flood?

No, but are you absolutely sure that if there was a flood on day 3 and you did not actually order the policy until day 46 and backdated it, the insurance company is actually going to pay the full claim.

I just find it interesting that insurance companies will sell insurance for events that have already happened. I wish all insurance worked like that.

Are you saying NO to the process of buy Forced Placed insurance on day 46 and back date the insurance to the date of expiration, is this practice acceptable


or are you saying NO to the process is not considered back dating?

It is not a problem unless you are chronically backdating the policies to cover up lender errors. Read the preamble to that question in the final rules as published in the Fed. Reg.

Federal Register /Vol. 87, No. 104 /Tuesday, May 31, 2022 /Rules and Regulations 32861

Although the Regulation states that a
lender may charge a borrower for the
cost of force-placed insurance beginning
on the date of lapse or insufficient
coverage, the Agencies note that
significant ‘‘backdating’’ of flood
insurance policies could indicate that
there are weaknesses with the lender’s
compliance management system.

Start force placing and charging on day 1 instead of day 46 to avoid any potential regulatory criticism.