Int Q&A – Force Placement 12 – If a lender receives a confirmation, …evidencing an overlap with a force-placed flood insurance policy, but the lender does not receive a refund from the insurance … is the lender still required to refund…?

Compliance > Lending > Flood > FAQs
Q:  Force Placement 12 – If a lender receives a confirmation, consistent with the Regulation, of a borrower’s existing flood insurance coverage evidencing an overlap with a force-placed flood insurance policy, but the lender does not receive a refund from the insurance provider of the force-placed flood insurance policy in a timely manner, is the lender still required to refund any premiums for overlapping coverage to the borrower within 30 days?
 
A:   Yes. The Regulation specifically requires the refund of force-placed insurance premiums and any related fees charged to the borrower for any overlap period within 30 days of receipt of a confirmation of a borrower’s existing flood insurance coverage without exception.
 
 
ADDITIONAL INFORMATION:
This Q&A was included in the Interagency Questions and Answers Regarding Flood Insurance, which were issued on 05/11/2022.  They were published in the Federal Register on 05/31/2022 and may be found here:  https://www.federalregister.gov/documents/2022/05/31/2022-10414/loans-in-areas-having-special-flood-hazards-interagency-questions-and-answers-regarding-flood
 

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