Q: On July 1, 2019, are all private flood insurance policies on file with the lender expected to be in compliance with either the compliance aid assurance clause or the mandatory purchase criteria? In other words, on July 1st, will it be necessary for the lender to send 45 day insufficient insurance notices to all private flood insurance policy holders with policies that do not have either the compliance aid assurance clause or meet the mandatory acceptance criteria?
A: The lender will not be required to review all its existing flood insurance policies on the effective date of the rule. On and after July 1st, 2019, lenders must accept any new private policies that meet the mandatory acceptance criteria and may, at their discretion accept policies that meet the discretionary criteria.
This Q&A was part of the discussion in the Outlook Live - Interagency Flood Insurance Update on Private Flood Insurance Rule webinar held on 6/18/19 and focused on the new private flood insurance rules that become effective 7/1/19. Information may be found here: https://www.webcaster4.com/Webcast/Page/577/30085