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We have an existing loan secured by property located in a SFHA where flood insurance is forced placed. We are going to refinance the loan into a new loan secured by the same property. The borrower wants to keep that same force placed flood insurance. However, our third party flood insurance company has said that force placed insurance is not transferrable and that they will need to cancel the existing flood insurance and then start the letter notification process for the new loan and force placed insurance. Would this be considered a violation of closing a new loan without adequate flood insurance? The policy would be effective back to the note date of the new loan.
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