A servicer has a reasonable basis to believe required hazard insurance is missing and sends an initial force-placed insurance notice. Before charging for coverage, what minimum initial-notice and reminder-notice intervals must it satisfy, assuming no evidence of coverage is received?
Correct Answer
D) Initial notice at least 45 days before charging; reminder at least 30 days after it and 15 days before charging
D. Satisfy the 45-day initial interval and the reminder's 30-day and 15-day constraints. The reminder cannot be delivered or mailed until at least 30 days after the initial notice. Assessment must be at least 45 days after the initial notice and at least 15 days after the reminder; the periods can overlap rather than necessarily totaling 60 days. Scope and exceptions: These are notice and assessment requirements for covered force-placed hazard insurance, not a rule requiring purchase to wait until day 45. A reasonable basis, compliant notices and absence of evidence of continuous required coverage remain necessary. Flood insurance and renewal notices have distinct rules. Source: Section 1024.37(a), (b), (c)(1), (d)(1) and (e) — https://www.consumerfinance.gov/rules-policy/regulations/1024/37/
Why This Is the Correct Answer
D. Satisfy the 45-day initial interval and the reminder's 30-day and 15-day constraints. The reminder cannot be delivered or mailed until at least 30 days after the initial notice. Assessment must be at least 45 days after the initial notice and at least 15 days after the reminder; the periods can overlap rather than necessarily totaling 60 days. Scope and exceptions: These are notice and assessment requirements for covered force-placed hazard insurance, not a rule requiring purchase to wait until day 45. A reasonable basis, compliant notices and absence of evidence of continuous required coverage remain necessary. Flood insurance and renewal notices have distinct rules.
Why the Other Options Are Wrong
Option A: Wait 45 days after the first notice, then always add a separate 15-day period
It unnecessarily starts the reminder interval only after 45 days.
Option B: Charge immediately after sending the initial notice
The initial notice does not permit immediate assessment.
Option C: Send one notice and charge after 30 days
It omits the reminder and shortens the initial interval.
Exam Tip
Track both notices; elapsed time alone does not authorize a charge.
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