A portion of the Biggert Waters reforms now requires that policies written after 7/6/12 which are for post-FIRM buildings can be issued a one-year tentative rate policy, but before that policy can be renewed, an elevation certificate must be obtained so that actuarial rates can be assessed when it comes time for renewal.
In the event that a borrower chooses not to go through this process and the Bank must force-place the insurance for the borrower after the 45-day wait from lapse of coverage –
is the Bank allowed to charge the cost of the elevation certificate to the loan balance, or is that a cost we would have to “eat” in order to obtain the flood insurance?