We identified that a loan did not have enough flood coverage and sent the 45 day letter, asking for proof of insurance no later than 8/24. We received communication from the borrowers insurance provider that insurance has been purchased and paid for. My problem is that the policy has a 30 day wait period making the effective date 9/4.

We asked that they waive the 30 day wait period due to it being in conjunction with a loan. They cited the new June 2014 Flood Guidelines page 9 C (emphasis added). Effective Date - New Policy 1. Standard 30-Day Waiting Period The effective date of a new policy will be 12:01 a.m., local time, on the 30th calendar day after the application date and the presentment of premium. This includes new policies obtained when a lender determines that flood insurance is required for an existing loan on a building that does not have flood insurance. (Example: a policy applied for on May 3 will become effective 12:01 a.m., local time, on June 2.)

Does this mean that we should force place insurance on 8/25 (46 days after our notice)? Which confuses me because in the past when we have forced placed the insurance has been effective on that date - so will we our force placed policies also have a 30 day wait due to the above comment?

so will we our force placed policies also have a 30 day wait due to the above comment?

If you are using the MPPP program, yes. If you are using private insurance, that will depend on your insurance company.

You do not have to wait until day 46 to force place insurance. You only have to wait until day 46 to charge the borrower. You can force place on the day you mail the 45 day letter in you so desire.