[TheBank]

We have received a flood insurance policy that seems to serve as some type of a master policy. There is a declarations page, but specific properties, coverage, and mortgagees are not stated. The company issues an Evidence of Property Insurance for individual properties covered that references the property name, amount, mortgagee, and deductible. The Evidence of property Insurance forms state the policy number for that master policy. We would not normally accept an EOI, but would the EOI work in this type of case with the master policy?

Also, the master police includes a statement similar to the compliance aid statement, but not exact, does it suffice? It sates a “Private Flood Insurance Guarantee” that includes “This policy meets all of the provisions required by the TItle II – Flood Insurance Act known as the National Flood Insurance Program.” Does that suffice for the compliance aid statement?

[Brent V]

Without seeing the master policy and the evidence of insurance I have to guess a bit. I assume that the master policy is used for every loan but means nothing by itself. Once the evidence of Insurance is issued, the combination of documents (master policy and EOI) creates the contract of insurance.

Since this is not a FEMA policy it must meet the definition of private flood insurance contained in 42 U.S.C. 4012a(b)(7) or contain the compliance aid statement. Since it does not contain the correct compliance aid statement, a full analysis of the private policy compared to a FEMA policy is required.

[Author]

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