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In certain instances our bank requires the borrower to maintain flood insurance in excess of the minimum requirement by the flood regulation. In some instances the borrower will obtain a $250,000 NFIP policy fro a dwelling and then obtain a private insurance policy for the remaining amount required. In this situation, the NFIP policy satisfies the requirements of FDPA. Would the bank be required to perform a review on the private policy if the compliance aid statement is not within the policy / stated on the declarations page? Would a review of the property covered, amount, bank as mortgagee, flood zone, and effective date suffice for the bank required private policy portion?
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