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Backdating of Force Placed Insurance

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I have a question related to long backdating (or just backdating) for force placed insurance. I am not finding a lot of information regarding backdating polices other than the standard 45 days that is required when placing a policy that has lapsed or expired. Does anyone know if there are current lawsuits concerning backdating a policy to an 'effective date' and charging the customer for that time even if nothing happened to their dwelling? For example, when we charge the customer on the 45th day of a new policy, but it is back dated to when their policy expired or lapsed, is this seen as a UDAAP issue with consumers? In essence we are charging them for a policy when they did not have a claim, so I am unsure what recommendations I should make regarding backdating polices. And, there are no kickbacks, this is simply a backdating question and premiums for servicing. I hope this makes sense! I am having difficulty finding any litigation and/or trends regarding this. Any feedback is welcomed. I am familiar with the process of 1024.37 however am looking a little deeper into the effective dates of polices placed, hazard or flood. Also cannot find much on Fannie Mae or Freddi Mac.

I know of no litigation pending on the issue, but I also am not aware of an insurance policy that will actually cover pre-existing damage to a property that occurred prior to the policy actually being issued.

First published on 07/17/2016

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