Flood insurance has expired. The force placement notice was not sent out immediately. Compliance review was done, and notice has been sent. Because the notice was not sent out immediately when the policy expired, the bank is in violation. Does the bank have to wait 45 days to force place flood insurance coverage, or can the bank force place at the bank's expense until the 45 days have gone by? I have never been through the process of force placing flood insurance. How is it done? If a borrower does not have enough insurance, can you just force place the difference needed?

I'm looking at the Mandatory Purchase of Flood Insurance Guidelines. It states 'if at any time during the term of a covered loan, the lender or servicer determines that the building securing the loan is not covered by flood insurance, or is covered by such insurance in an amount less than that required by law, the lender or servicer must first notify the borrower of the need to carry adequate flood insurance coverage. If the borrower fails to purchase such flood insurance within 45 days after such notification, the lender or servicer shall purchase the insurance on behalf of the borrower and may charge the borrower for the cost of premiums ad fees incurred by the lender or servicer.'

Look a page 37-40 of the Mandatory Purchase of Flood Insurance Guidelines.

As I read this, you do have to wait the 45 days after you notify the borrower, and I would also say yes that you could force place the difference if the borrower refused to acquire adequate coverage.