[Anonymous]

If our bank has to force place flood insurance, we add the premiums and fees to the principal amount of the loan so it is capitalized, as stated in the loan contract.
With the Biggert Waters mandatory refunding of premiums and fees when coverage overlaps, are we also required to refund any interest accrued due to the premiums and fees? My initial thoughts are yes.

[jholzknecht]

Your initial thought is the safe answer. Remember, at this point we have only the bare bones provisions of the law; we do not have regulations. Once regulations are published we hope they will provide adequate details including answers to questions like yours.

[Author]

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