I have a question related to long backdating (or just backdating) for force placed insurance.
I am not finding a lot of information regarding backdating polices other than the standard 45 days that is required when placing a policy that has lapsed or expired.
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The application was after that date and intent of notice to proceed has not yet been obtained.Internal mortgage compliance audit cited violation of 1026.19(e)(2) stating check to realtor should have been dated after ITP.I think they are wrong - since that independent transaction happened outside of the control of the financial institution.In essence we are charging them for a policy when they did not have a claim, so I am unsure what recommendations I should make regarding backdating polices.And, there are no kickbacks, this is simply a backdating question and premiums for servicing. I am having difficulty finding any litigation and/or trends regarding this. I am familiar with the process of 1024.37 however am looking a little deeper into the effective dates of polices placed, hazard or flood. My question is regarding earnest money deposits on a residential mortgage real estate transaction.