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.
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The opinions expressed are mine and they are not to be taken as legal advice.