One commenter requested clarification on whether the 45-day notice could be sent prior to the actual date of expiration of flood insurance coverage. “Several commenters requested clarification regarding timing issues related to the 45-day notice. The regulators had the following to say regarding the new proposed questions within the preamble to the Jissuance: The only reason that questions 60 thru 62 were included as “proposed” in the Jissuance is the fact that they were not included in the original MaQ&A proposal and all Q&As go out first as proposed, even those Q&As that the regulators have no leeway to change. While it is true that question #62 is still out for comment, it does not necessarily mean that it is not a current requirement. The vendor in this case was pushing back - here is a copy of my correspondence with the bank regarding the force placement on the day of expiration:
You are probably using the same vendor as one of my clients.
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