If I understand the force-placed insurance part of the regulation, we can charge the borrower for the force-placed coverage after 45 days (ie two notices) of expiration.

So, we are notified on October 1, that coverage was cancelled on September 10. If we choose to force-place coverage on October 1, we could be out the premiums if the borrower provides proof of coverage prior to end of the 45th day, unless they were continuously uninsured for some period of time in which case, we can recoup some. If we wait until the 45th day to force-place and the unthinkable happens (fire) destroying the property between expiration and the 45th day, we are at a loss.

If this is correct, when are other banks force-placing coverage? Day 1, or Day 45. If my understanding of this is incorrect, please explain.

Thank you

We have the same question...

I am looking for help with this also!!

I don't know how to link to previous threads but I thin the following (if it works, it asnwers our question)

http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1816747#Post1816747

We are planning on force placing on day 1. But we are going to send out the first 45 day letter prior to the actual expiration of the policy. If I'm reading the new rule correctly, unlike flood insurance, you don't have to wait until the policy is expired to start the 45 day process.

"we could be out the premiums if the borrower provides proof of coverage prior to end of the 45th day"

Why? Most force placed insurance providers allow you to retroactively cancel insurance policies if you determine that the borrower was actually insured for all or part of the time. If not, then you need to be visiting with your force placed provide or explore some other providers.