October 2011 FAQ #63 & 64.

#63 Addresses whether or not a private policy may be used in lieu of a NFIP policy as long as the policy meets certain criteria (paraphrased).

#64 Addresses private policies that do not meet the criteria. Additionally #64 mentions "private policies providing portfolio-wide blanket coverage" and that it could be relied on for gap coverage for the period of time before a forced policy takes effect.

So here is my question: Does that fact that #64 addressed blanket wide portfolio coverage in the context of a policy that does not meet the criteria mean that a portfolio wide blanket coverage policy that does meet the criteria can be relied on in place of a forced place individual policy?

As you may have surmised by my question, Sr Management is wondering if we could purchase a portfolio-wide blanket coverage policy to be used in place of forced place coverage. My instincts are No but I'm not sure I can find chapter/verse that clearly supports my instinct.

Comments/thoughts/interpretations are all welcomed.

Your instincts are correct. They are referring to the bank purchasing blanket wide portfolio coverage to cover gaps in coverage, i.e., you don't force place a private policy until your 45 day letter expires and if the customer had a NFIP policy that expired, then you would have a 15 day gap in coverage between the time the mortgagee protection expired on the NFIP policy and when you force placed the policy.

Since you ultimately have to force place a policy on behalf of the borrower, thus the borrower has to be a named insured on the policy, I have never seen a blanket policy able to do that.

Thank you rlcarey; very helpful.