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I have never been clear on this but if we have a real estate loan we had to force place flood insurance and that policy is up for renewal do we have to mail out a 30 day letter to the borrower? I mail the 45 day letter initially after the day of expiration but I could not find guidance that a 30 day letter needs to be sent on renewals of forced flood.
The flood regs address the intial force-placement. See Q&A #10 from this interagency q&a on renewal of a force placed policy.
Also, the MPPP has rules related to renewal of MPPP policies – see page #11. https://www.fema.gov/media-library-data/1478271984247-21328c353d6c693452112933906eb219/MPPP_Guidelines_Requirements_2017FY.PDF. I think for a renewal of a force-placed policy you can use the same protocol outlined for the MPPP.
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