Q: If we have a private flood insurance policy currently in place and it comes up for renewal after 7/1/19, do we need to review the policy under the mandatory acceptance criteria in order to allow continued use of that policy post renewal? What if the private policy does not meet the criteria?
A: So, once the policy comes up for renewal it would be necessary for the lender to review it although there is no regulatory requirement to review policies currently in place, once the policy comes up for renewal it should be handled as though it was a new policy. In other words, a lender would have to review all policies that are new or renewed after July 1st, 2019, to make sure the policies comply with the regulation.
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