[HMDA Guy 78]

Thanks, Robin. So – if we had building only coverage, then we are not technically in violation of flood regulations, and it is more of a safety-and-soundness issue?

Also… is it correct to say that the total coverage of building coverage plus contents coverage combined must be equivalent to the “lesser of the three” for sufficient coverage? Or in this case, would you treat each loan as a separate entity (i.e. building coverage must equal loan #1 amount, and contents coverage must equal loan #2 amount)?

[HMDA Guy 78]

Has anyone had to force-place a policy since 10/1/13? Just today I became aware that effective 10/1/13, the “no waiting period” for lender required policies not in connection with a loan transaction (i.e. “force-placed policies”) has been eliminated. This means that if I ordered a force-placed policy today and we made the payment to our local insurance agent vendor, that the policy would not take effect for 30 days until 11/25, whereas before it would be effective today – date of payment.

I am wondering how this elimination of the “no wait” period is going to affect us with the 45-day timing. We have two customers who – while not in writing – have in practice for years relied on the Bank to do the force-placing of their flood insurance (except the initial year in connection with their loan closing). Do I now have to “order” and get payment made on day 16 after expiration of the policy, so that on day 46 – 30 days later – the policy is in effect?

I can’t see any other way around it yet but I need to dig into the changes more….

Here is a link to some changes effective 10/1/13 for anyone interested:
https://www.floodpro.net/Shared/Generic/News/BW_October_2013_changes.pdf

Any thoughts are welcome!! Help. 🙂

[HMDA Guy 78]

Thanks, Robin. Those were my initial thoughts – just having doubts since I couldn’t find anything in the reg or commentary specifically saying as much. I appreciate your help!

[HMDA Guy 78]

I would agree, Robin – my concern is … if the borrower doesn’t sell his other home, and we have to refinance the loan into long-term financing, is there an issue in us reporting HMDA twice on it? Because in that case it would be a refinance for Reg C / HMDA purposes.

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