Question:
I received a private flood policy for a commercial loan with 24 structures located in a flood zone. The coverage amount is over $3 million more than what is required. However, based on the definition of "Private Flood Insurance," the policy does not meet all of the requirements. Are there any best practices or additional guidance besides the proposed rules that are not finalized? We are a member in this syndicated deal and the agent bank is willing to accept the risk of not having all of the required items. Given our bank must perform our due diligence separately, I am not comfortable accepting the policy as is and am looking for guidance on something I may be missing.