The
News and Views From WNC Insurance Services, Inc.
2013 Edition Number 1
In This Issue:
Page 2
Compliance Corner
Page 3
Hot Issues
Page 4
Claims Corner
Page 5
Who is WNC?
Technology Bulletin
Page 6
Hot Issues-continued
For additional information or clarification regarding
any of the articles published in The Guardian, please
contact Ms. Paula Anders, WNC Marketing Manager
at [email protected].
Atlantic Hurricane
Names
Andrea
Lorenzo
Barry
Melissa
Chantal
Nestor
Dorian
Olga
Erin
Pablo
Fernand Rebekah
Gabrielle Sebastien
Humberto Tanya
Ingrid
Van
Jerry
Wendy
Karen
2013
Source: NOAA/ National Weather Service
From The CEO
How do you best describe WNC First?
by Carl L. Herrmann III, CEO
President, Financial Services Division
Besides WNC First being an MGA, providing insurance-specialty
programs to various markets, and a group of creative, motivated,
customer-focused professionals, what else do you know?
I bet you didn’t know:
Carl L. Herrmann III, CEO
•40% of the business we underwrite is in the non-lender placed,
President, Financial
voluntary market.
Services Division
•WNC First produces in excess of $100 million of annual premium to the Lloyd’s market.
•WNC First’s claims company, Precise Adjustments, is administering in excess of $50
million in claims payments to Super Storm Sandy victims.
•WNC First’s Precise Adjustments handled more than 5,000 Sandy claims—over 4,000 of
those were for non-WNC First MGAs and carriers.
•We added 500,000 loans from various lenders and servicers in 2012 where WNC First
provides tracking and insurance programs.
•WNC First provides underwriting expertise in Flood to two major US insurance
companies for their Private Flood programs. We oversee $17 billion of coverage on an
admitted and non-admitted basis, annually.
We are doing some exciting, diverse, and meaningful insurance programs here at WNC First.
So the next time you’re asked a question about WNC First, or better yet, you’re asked what
they do, you might just say, “What don’t they do!”
From The Co-President
New Season, Challenges
and Opportunities
by Norman G. Heinrich
President, Voluntary Division
It’s hard to believe that it’s already June. Everything is moving so
fast that it is Hurricane Season once again and we have not even closed
out the 2012 Hurricane Season losses. We continue to work our way
through the aftermath of Super Storm Sandy and the rebuilding is just
Norman G. Heinrich
starting for many in the Northeast. What does 2013 have in store for us? President, Voluntary
Division
We can only hope Mother Nature is kinder to us than she was in 2012.
Another loss like Sandy would put significant pressure on the insurance
industry, especially the flood markets. The NFIP is significantly in debt and the number of open
Sandy flood losses remains a problem.
The WNC Voluntary Flood programs are experiencing increased quoting activity with interest
from across the country. I fully expect the 2013 Hurricane Season will bring strong demand
especially if the hurricane season proves active as the experts are predicting.
Our flood programs now cover almost any type of property from commercial to residential
and from coastal to inland. It seems like no matter where a storm might make landfall, a WNC
property will be affected. I congratulate everyone involved with the handling of the Super Storm
Sandy losses and feel proud that WNC again performed well in another tough situation.
Compliance Corner
Some of the areas tested include:
IT’S OFFICIAL – WNC IS
SSAE 16 TYPE II CERTIFIED
• Enrollment and Underwriting
• Premium Reporting
• Claim Processing
• Aggregate Reporting
by Jordan N. Gray, Esq., Senior Vice
President, Compliance and Legal Affairs • Insurance Tracking
• Licensing Compliance
For the second year
• Data Backup
in a row, WNC received • Logical Security
an Unqualified Opinion • Physical Security
on our SSAE 16, SOC
Well done SSAE 16 Team and thank
1 Type II Report, which
you BDO!
means WNC First
Insurance Services is
once again proven to be BIGGERT-WATERS:
a “trusted advisor.”
A Cascade of Questions
escrow rule (which also needs regulation
written), which becomes effective 2 years after
Biggert-Waters was signed into law. The second
question is, “When will the federal regulators
comply with Biggert-Waters?”
Waiting for revised Mandatory Purchase
Guidelines
In light of the significant changes under
Biggert-Waters, FEMA officially withdrew
its Mandatory Purchase of Flood Insurance
Guidelines. The Guidelines have been the
go-to book for lenders since the beginning.
In fact, the Interagency Questions and
Answers on Flood Insurance published by
the federal lending regulators rely upon and
cite the Guidelines as support for compliant
For nearly 20 years since 1992, the U.S.
industry practice. Thus, the American
without Answers
Statement on Auditing Standards No. 70 (SAS
Bankers Association recently urged the federal
by Jordan N. Gray, Esq., Senior Vice
70) has been the leading standard for service
regulators to publish the Guidelines. The third
President, Compliance and Legal Affairs and fourth questions are, “Will the federal
organization reporting. In 2011, the Statement
on Standard for Attestation Engagements (SSAE
agencies publish the Guidelines and will they
On July 6, 2012, the Biggert-Waters Flood
16) replaced SAS 70 as the newly released
Insurance Reform Act of 2012 (the “Act”) was publish revisions to Interagency Flood Q&A?”
auditing standard of the American Institute
Some Waiting may be Over
signed by the President. The Act extends the
of Certified Public Accountants (AICPA) for
National Flood Insurance Program (“NFIP”) In Fannie Mae Selling Guide Announcement
reporting on financial service organizations.
authority through September 30, 2017. After
SEL-2013-03 (April 9, 2013), Fannie Mae
The main motivations behind SSAE 16 are:
nearly ten months since the Act was passed,
affirmatively announced that it accepts private
we in the industry have learned a lot about
• Increased globalization of information
flood insurance as required under Biggertwhat we don’t know as we experience a
technology and business outsourcing
Waters. Fannie Mae notes that the terms and
cascade of questions without answers.
• Increased regulatory scrutiny in financial
amount of coverage provided under a private
reporting
policy must be at least equal to an NFIP
Waiting for Answers to Biggert-Waters
• Increased unification of US and
policy. So the fifth question is, “Will Fannie
Compliance
international auditing standards
Mae revise its guidelines after FEMA and
For example, sections 100204 and 10228
As with SAS 70, there are two types of
(multifamily properties), 100205 (rate reform), the federal regulators comply with BiggertSSAE 16 audits, Type I and Type II. A Type I
100207 (rate adjustments), 100210 (minimum Waters?” Fannie Mae’s approach is simple and
straightforward.
audit would only look at a point in time (e.g.
deductibles), 100214 (condo claims), and
January 31, 2013). However, a Type II audit,
which is what we completed, would look at a
period of time (August 1, 2012 – January 31,
2013). Additionally, Type I only examines the
design of internal controls while Type II audit
examines both the design and the effectiveness
of those controls.
Our Auditors
Our SSAE 16 audit was performed by BDO
USA, LLP – a well-respected, independent
auditing firm and US member firm of the
world’s fifth largest international accounting and
consulting firm. Therefore, a successful SSAE
16 audit by BDO means credibility, integrity
and authority.
The Audit Tests
It was a rigorous six-month auditing period
where WNC’s internal and financial controls
were reviewed and tested for completeness,
consistency, and correctness.
2
The GUARDIAN
100234 (policy disclosures) are dependent
upon FEMA’s compliance timetable. Lenders,
servicers and their insurance vendors cannot
require these coverage limits or policy features
if FEMA has not made them available. FEMA
recently announced that its Biggert-Waters
compliance will occur on or after October 1,
2013. The first question is, “When will FEMA
comply with Biggert-Waters?”
We think the federal regulators need to let the
insurance professionals advise the lenders when
a private flood insurance policy complies with
the lender’s requirements. Isn’t that how hazard
insurance requirements are currently handled?
Fannie Mae has the right idea. Keep it simple.
We hope FEMA and the federal regulators will
do the same.
Likewise, sections 100209 (flood escrow),
100222 (RESPA notices), 100239 (private
flood insurance), 100244 (insurance charges),
and 100208 (enforcement) are dependent upon
the federal regulators’ compliance timetable.
Lenders, servicers and their insurance vendors
cannot implement these provisions if the
federal regulators have not written new
regulations. The federal regulators recently
announced that their Biggert-Waters
compliance target is July, 2014. This
corresponds with the mandatory flood
This article is a publication of WNC Insurance
Services, Inc. and intended for informational use
only. WNC Insurance Services, Inc. is not engaged
in rendering legal advice or recommendation. If
you require legal guidance, please consult your
legal counsel or a professional law practitioner.
For comments, please call your WNC representative
or our offices at 1-800-423-2497 and ask for the
Compliance Department.
So we wait.
2013 Edition Number 1
Hot Issues
The Next Time The
Regulators Come Calling
…Will You Be Ready?
by Sheri Kordsmeier, Vice President,
Business Development
The Consumer Financial Protection Bureau
(CFPB) and other regulatory agencies expect
you to develop and implement policies for
risk management and governance of your
company’s vendors. Are you ready? If not,
now is the time to evaluate your vendor
management processes and software tools to
ensure you are ready for your next audit.
It is critical to your business to ensure
that your third-party products and services
comply with applicable laws and security best
practices. From due diligence, risk assessment,
planning and contract review to ongoing
monitoring and oversight, you must develop a
comprehensive vendor management process
and obtain a complete view of your vendor
relationships and risks.
CFPB NOTICE LETTERS
– A Short Primer
by Jordan N. Gray, Esq., Senior Vice
President, Compliance and Legal Affairs
On January 17, 2013, the Consumer
Financial Protection Bureau (“CFPB”) issued
its final rules regulating Mortgage Servicing,
including a final rule on Force-Placed Hazard
Insurance. WNC’s compliant notice letter
templates will be available for our clients well
before the effective date of the Final Rule.
The Final Rule is effective January 10, 2014.
The following is our “primer” on the Final
Rule regarding the initial force-placed hazard
insurance notice letter cycle.
CFPB Force-Placement Requirements
– Written Notice
Servicers must meet three general
requirements before a borrower can be
charged for forced-placed coverage. They
are: (i) Send a 45 Day Notice Letter to the
borrower; (ii) Send a 15 Day Reminder Notice
Letter to the borrower, 30 days after the first
notice letter; and (iii) Fail to receive proof of
continuous hazard insurance coverage that
complies with the loan agreement, before
the end of the second notice letter period.
(Sections 1024.37(c)(1) and (d)(1)) Here’s
our summary of the notice letter requirements.
Through WNC, you can obtain a vendor
management solution that is comprehensive,
compliant and cost effective. Quantivate
Vendor Management provides a legal
framework that complies with current
FDIC/OTS/OCC/CFPB requirements; due
diligence and risk assessment capabilities;
and easy-to-use software tools to manage
and monitor your vendor relationships
starting today.
With Quantivate, you can manage all your
vendor contacts and contracts, financials
and insurance certificates through a
web-based application that also allows
you to quickly perform due diligence
by automatically calculating a vendor’s
scores on multiple variables to obtain
a composite risk profile.
The Quantivate Difference
•The Quantivate team brings proven
implementation methods to each
customer engagement.
•The Quantivate software platform
is intuitive and easy to use.
First Notice
Forty-Five Day Notice: At least 45 days
before coverage is force-placed, a servicer
must send a written notice to the borrower
containing the following information;
1.The date of the notice;
2.The servicer’s name and mailing address;
3.The borrower’s name and mailing
address;
4.A statement in bold text requesting proof
of hazard insurance for the borrower’s
property, identified by its physical address;
5.A statement that the servicer does not have
evidence of hazard insurance, as identified,
past the stated expiration date;
6.A statement in bold text that the servicer
has purchased or will purchase, the
required hazard insurance at the borrower’s
expense;
7.A statement requesting the borrower to
promptly provide the servicer with
insurance information;
8.A description of how the borrower may
provide the requested insurance
information to the servicer;
9.A statement in bold text that the servicer’s
insurance:
a.May cost significantly more than the
borrower’s insurance;
b.May not provide as much coverage as
the borrower’s insurance;
•Free unlimited training ensures maximum
benefit.
•Quantivate provides globally integrated
product support services.
Get ready to join many financial institutions
that have successfully passed regulatory audits
with Quantivate Vendor Management. Call
your WNC representative today to learn more
or to schedule your complimentary demo.
For more information or a demo, please contact
Sheri Kordsmeier, Vice President, Business
Development at 800.423.2497, Ext. 6311.
10.The servicer’s telephone number for borrower
inquiries; and
11.If applicable, a statement advising the
borrower to review additional information
provided in the same transmittal. (Section
1024.37(c)(2))
Format Note: Certain portions of the 45 Day
Notice Letter need to be in bold text, as noted
above. (Section 1024.37(c)(3)) Although this
can be confusing, the CFPB provided a model
template, form MS-3A, to assist with compliance.
The CFPB model forms are available on our
website at http://www.wncfirst.com/portal/news.
asp.
Additional Information: A servicer may not
include within the 45 Day Notice Letter any
information other than as required by Section
1024.37(c)(2). However, a servicer may reference
additional information provided on a separate
paper. (Section 1024.37(c)(4))
Second Notice
Fifteen Day Reminder Notice: At least 30
days after the first notice, a servicer must send
a reminder notice to the borrower at least 15
days before coverage is force-placed (Section
1024.37(d)(1)). The reminder notice must
respond in either one of two ways, No Coverage
or No Continuous Coverage:
No Coverage: If the servicer did not receive
proof of insurance after the first notice, the
continued on page 6
2013 Edition Number 1
3
The GUARDIAN
Claims Corner
NOAA Predicts Active
2013 Atlantic Hurricane
Season
by Mark Sarrett, Chairman, Precise
Adjustments, Inc.
For the 2013 hurricane season from June 1
to November 30, NOAA’s Atlantic Hurricane
Season Outlook says there is a 70 percent
probability of 13 to 20 named storms (winds
of 39 mph or higher), of which 7 to 11 could
become hurricanes (winds of 74 mph or
higher), including 3 to 6 major hurricanes
(Category 3, 4 or 5; winds of 111 mph or
higher). These are above the seasonal average
of 12 named storms, 6 hurricanes and 3 major
hurricanes.
The following factors that strongly control
Atlantic hurricane activity are expected
to come together to produce an active or
extremely active 2013 hurricane season:
• A continuation of the atmospheric climate
pattern that includes a strong west African
monsoon, which is responsible for the
ongoing era of high activity for Atlantic
hurricanes that began in 1995;
• Warmer-than-average water temperatures
in the tropical Atlantic Ocean and
Caribbean Sea; and
• El Niño is not expected to develop and
suppress hurricane formation.
NOAA’s seasonal hurricane outlook does
not predict how many storms will hit land or
where a storm will strike. Individual storm
forecasts are provided by NOAA’s National
Hurricane Center.
Insured Value of U.S.
Coastal Properties Now
More Than $10 Trillion
In an article by Rodd Zolkos and published
in www.businessinsurance.com, he wrote
that the total insured value of residential and
commercial properties in coastal communities
of the U.S. is now greater than $10 trillion, of
which over a third are located in the Gulf and
East Coast states.
The coastal exposures along the Gulf and
East Coast represent almost 16% of the total
property value in the U.S., according to AIR
Worldwide Corp.’s 2013 “The Coastline at
Risk” report. Updated from a 2008 version
2013 Edition Number 1
New for this hurricane season are
improvements to forecast models, data
gathering, and the National Hurricane Center
communication procedure for post-tropical
cyclones. In July, NOAA plans to bring
online a new supercomputer that will run an
upgraded Hurricane Weather Research and
Forecasting (HWRF) model that significantly
enhances depiction of storm structure and
improves storm intensity forecasts.
Also this year, Doppler radar data will
transmit in real time from NOAA’s Hurricane
Hunter aircraft, helping forecasters better
analyze rapidly evolving storm conditions
and improve the HWRF model forecasts by
10 to 15 percent.
NOAA predicts a below-normal hurricane
season for the Eastern Pacific and Central
Tropical Storm Andrea photo as taken by NASA
of the same report, New York has overtaken
Florida as the state with the highest value of
coastal properties at almost $3 trillion.
The same AIR report further stated that even
Pacific basins. NOAA will issue an updated
outlook for the Atlantic hurricane season in
early August, just prior to the historical peak
of the season.
JUNE 6 & 7, 2013: TROPICAL
STORM ANDREA BREAKS
29 RAINFALL RECORDS!
Location
Rainfall In Inches
New
Record
Old
Record
Year
Worcester, MA
2.68
1.75
2006
Hartford, CT
2.53
1.54
1913
Providence, RI
3.23
3.08
2006
Boston, MA
3.07
2.89
2006
Massena, NY
0.72
0.43
1984
Syracuse, NY
2.39
1.20
2010
Trenton Mercer Airport, NJ
3.51
1.60
1989
Islip, NY
4.15
1.27
2006
Kennedy, NY
4.01
1.18
2006
LaGuardia, NY
3.33
1.08
2006
Central Park, NY
4.16
1.95
1918
Bridgeport, CT
4.43
1.36
2006
Newark, NJ
3.71
1.11
1931
New Castle County Airport, DE
3.36
1.78
1916
Lehigh Valley Int’l Airport, PA
1.82
1.19
1948
Philadelphia Int’l Airport, PA
3.50
1.79
1904
Salisbury, MD
1.58
1.43
1913
Richmond, VA
2.67
1.68
1913
Fayetteville Regional Airport, NC
2.36
1.78
1930
Raleigh-Durham Int’l Airport, NC
5.14
1.24
1930
New Bern, NC
1.51
1.2
2003
Asheville Regional Airport, SC
3.42
1.24
2003
Fort Lauderdale, FL
8.15
1.88
1960
Naples, FL
1.48
1.20
1991
Vero Beach, FL
2.74
2.43
1983
Melbourne, FL
2.02
1.94
2009
Lynchburg, VA
3.38
3.31
1989
Roanoke, VA
1.77
1.15
1934
Blacksburg, VA
2.70
1.09
1961
if the annual growth rate of coastal property
values fell from 7% to 4% in the past five
years due to the recession, “indications are
that, as the economy recovers, the rate of
growth will pick up.” At a historical
rate of 7%, the total insured value
would double every decade.”
Please contact your WNC
representative if you would like
information on WNC’s hazard,
wind and flood insurance programs
for mortgage loan portfolios.
(Sources: “Insured value of U.S. coastal
properties tops $10 trillion: Analysis” by
Rodd Zolkos, www.businessinsurance.
com; photo by nytimes.com)
The GUARDIAN
4
Who is WNC?
Meet Leila Taha
Meet Lisa Fanning
Scott Jefferies is Senior
Vice President of Dallas
Operations, responsible
for tracking activities
that include mail, data
capture, OCR, data
Scott Jefferies,
processing, customer
Sr. Vice President,
Operations
service call center and
lender services management.
Scott began his career some 28 years ago
as a renewal processor in the insurance
department at Lomas Mortgage in Dallas,
Texas. Since that beginning, he has worked
in different executive positions at several
mortgage servicers and banks, among them
Capstead Mortgage and Saxon/Morgan
Stanley. He spent seven years in the tax
outsourcing arena, working for large servicers
such as GE Capital, GMAC Mortgage, and
Chase.
Much of Scott’s work history has been
focused on developing and executing
strategic operational initiatives related to
start up and turn around opportunities. He is
extremely excited to be back in the insurance
environment.
He holds a BA from Brigham Young
University, was a former Jr. High educator,
and lives in Plano, Texas.
As Vice President
of Development &
Voluntary Operations,
Leila is responsible for
overseeing management
and enhancement of
systems that support
Leila A. Taha,
WNC’s voluntary
Vice President,
product lines, as well
Development &
Voluntary Operations as helping to develop
strategies for the
development and expansion of the division’s
offerings. Leila brings more than 18 years
of National Flood Insurance Program
experience to WNC, assuming various roles
from operations to business development.
Leila is excited about joining WNC because
it is “an opportunity to not only be part of a
great team but also to learn more than I ever
thought possible about ‘flood’!”
Leila has been an officer of the National
Flood Determination Association (NFDA)
since 2003, including serving as President
from 2008-2010. She is a regular speaker
and participant at FEMA’s National Flood
Conference and at other flood-related events
across the nation.
Leila holds a Bachelor of Arts degree
in Biogeography from the University of
California at Los Angeles (UCLA). When not
in the office, she enjoys traveling, yoga, the
arts and the pursuit of good coffee.
Lisa Fanning is Vice
President of Special
Projects, reporting to
Carl Herrmann III.
Her first projects will
be to focus on Teneo
documentation and
Lisa Fanning,
training of the Operations
Vice President of
staff, as well as preparing
Special Projects
overall WNC compliance
documents and specific lender information
for CFPB vendor requests.
Lisa began her career some 20 years ago
at PriceWaterhouse Coopers, formerly known
as Coopers & Lybrand, as a consultant in the
Entertainment and Public Assembly Facilities
division. She then moved into various positions
at several mortgage and commercial servicers,
among them Capstead Mortgage, GMACRFC, Archon/Goldman Sachs, Saxon/Morgan
Stanley and recently NationStar Mortgage.
Much of Lisa’s work history has
been focused on various forms of loan
administration servicing functions such as
acquisitions, imaging and project management.
She is excited for the opportunity to learn and
grow in a new area of financial services.
Lisa holds a BA in Finance from the
University of Texas at Austin and an MBA
from the University Of Houston. When not
in the office, she enjoys cycling, walking
and traveling.
Technology Bulletin
Ready for Launch:
Voluntary Flood Agency
Management System
Upgrade
ready for their hard work to yield results.
Our agents are ready to begin using the new
system and take advantage of its greater
functionality.
At WNC, we make the changes necessary
to keep our systems ready and able to handle
the innovative and unique products that built
our reputation and the greater benefits they
bring to our clients.
Meet
Scott Jefferies
For more information on our Voluntary Flood
System upgrade, feel free to contact: Gregory
Baltzer, Sr. Vice President, Information Technology
(626) 463-6400, ext. 6315, [email protected]
by Gregory Baltzer, Sr. Vice President,
Information Technology
Our Voluntary Flood product team, working
closely with IT and our new carrier, has been
working on a significant upgrade to our
Voluntary Flood program for commercial
properties. With the upgrade, agents will be
able to schedule multiple property locations
on a single “master policy”, making it easier
to add or remove individual property locations
as needed. The system upgrade comes with a
new GUI (Graphical User Interface) making
navigation easier for users. We have also
streamlined our internal procedures for
maximum advantage.
Everyone at WNC who is involved in this
system project is anticipating its release and
5
The GUARDIAN
FEMA/David Saville
2013 Edition Number 1
Hot Topic continued from page 3
reminder notice must contain the following
information:
1.The date of the notice;
2.A statement in bold text that the notice
is the second and final notice;
3.A repeat of the information stated in the
first notice (2-11, above); and
4.The cost of the force-placed insurance,
in bold text, stated as an annual
premium. (Section 1024.37(d)(2)(i))
No Continuous Coverage: If the servicer
received proof of insurance after the first
notice, but the proof does not demonstrate
continuous coverage, the reminder notice
must contain the following information:
1.The date of the notice;
2.A statement in bold text that the notice
is the second and final notice;
3.The servicer’s name and mailing
address;
4.The borrower’s name and mailing
address;
5.A statement in bold text requesting
proof of hazard insurance for the
borrower’s property, identified by its
physical address;
6.The cost (or estimated cost) of the
force-placed insurance, in bold text,
stated as an annual premium;
7.The servicer’s telephone number for
borrower inquiries;
8.A statement that the servicer has received
the hazard insurance information that the
borrower provided;
9.A statement requesting the borrower to
provide missing information;
10.A statement that the borrower will be
charged for the servicer’s insurance during
any gap in the borrower’s coverage; and
11.If applicable, a statement advising the
borrower to review additional information
provided in the same transmittal. (Section
1024.37(d)(2)(ii))
Format Note: Certain portions of the 15 Day
Reminder Notice Letter need to be in bold text,
as noted above. (Section 1024.37(d)(3)) Although
this can be confusing, the CFPB provided model
templates, forms MS-3B and MS-3C, to assist
with compliance. The CFPB model forms are
available on our website at http://www.wncfirst.
com/portal/news.asp.
Additional Information: A servicer may not
include within the 15 Day Reminder Notice
Letter any information other than as required by
Sections 1024.37(d)(2)(i)-(ii). However, a servicer
may reference additional information provided on
a separate paper. (Section 1024.37(d)(4))
Updated Notice: If new insurance information
is received after the 15 Day Reminder Notice
Letter was put into production, the servicer is
not required to update the notice with the new
information if the notice is sent to the borrower
within a reasonable time after being placed
into production. The CFPB commentary states
that five business days is a “reasonable time”.
(Section 1024.37(d)(5))
For a complete discussion of the Force-Placed
Hazard Insurance Final Rule and the CFPB
notice letter templates, please visit our website
at http://www.wncfirst.com/portal/news.asp
or look for the February 5, 2013 edition of
Compliance Matters entitled “CFPB Issues Final
Rule on Force-Placed Hazard Insurance” written
by this author also on our website at http://www.
wncfirst.com/wncinsserv/downloads.asp.
This article is a publication of WNC Insurance
Services, Inc. and intended for informational use
only. WNC Insurance Services, Inc. is not engaged
in rendering legal advice or recommendation. If you
require legal guidance, please consult your legal
counsel or a professional law practitioner. For
comments, please call your WNC representative
or our offices at 1-800-423-2497 and ask for the
Compliance Department.
899 El Centro Street • South Pasadena, CA 91030
www.WNCInsuranceServices.com
Corporate Home Office
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