Renewal of Force-placed insurance

The bank has force placed homeowners insurance in place on a loan. At the one-year renewal, the staff failed to provide the customer with the required 45-day renewal notice.

Is there any correction for this error, or would we just not be allowed to pass the fee on to the customer this year since it wasn't properly disclosed at renewal?

I am not sure that there is any guidance for this error. I think the bank eating the entire year premium is a little steep for a penalty however. I would send the 45 day notice now and then not charge the borrower for the time between the last expiration date of the force placed policy to the time that the 45 day letter expires.