30-Day Wait on Flood Insurance Policies
Flood Insurance rules are not easy and we still see both bankers and insurance agents that don’t know the rules. One common instance is regarding the 30-day waiting period for flood insurance. You would think this would be a pretty simple concept but whether there’s a 30-day wait or not depends on various factors.
The 30-day wait does NOT apply to:
1. The purchase of flood insurance when the purchase is in connection with making, increasing, renewing or extending a loan; or
2. The initial purchase of flood insurance in connection with a map change/revision that moves a structure into an SFHA (within a 13-month period).
The 30-day wait DOES apply to a loan where the flood insurance policy has expired. However, a Standard Policy allows for a 30-day grace period after the expiration date to reinstate the policy and keep continuous coverage. Thus, if the borrower pays the premium BEFORE the 30-day grace period ends, there is NOT a 30-day wait before the policy takes effect.
The 30-day wait also applies to Mortgage Portfolio Protection Program (MPPP) insurance. For example, a borrower’s policy expires and the premium is not paid before the 30-day grace period ends – if the Lender force places with MPPP insurance, the 30-day wait applies. A Lender may force place the MPPP insurance after the policy expiration date, rather than waiting until after the 30-day grace period ends to avoid a lapse in coverage. However, the Lender cannot charge the borrower for the insurance until day 46, after the 45-day notification requirement has ended.
Published
2015/03/19
Deb Irving
David Dickinson
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.