Answer by David Dickinson:You are not making, renewing or increasing a loan, but you do have knowledge of an under-insured loan, which is one of the tripwires listed on page 54 of the FEMA Guidelines. I believe you must notify the borrower of the need for adequate insurance and force place if they don't purchase it within forty-five days after notification.
Answer by Randy Carey:This is further supported by Q#57 in the recent Flood FAQ:
57. What is the requirement for the force placement of flood insurance under the Act and Regulation?
Answer: The Act and Regulation require a lender to force place flood insurance, if all of the following circumstances occur:
• The lender determines at any time during the life of the loan that the property securing the loan is located in an SFHA
First published on BankersOnline.com 2/15/10