We do not believe that anything in the Flood Disaster Protection Act of 1973 would prohibit a bank from force-placing flood insurance before the end of the forty-five day notification period, provided that you do not charge the customer for the insurance until the forty-five day period ends. See 42 USC 4012a(e). However, note that if a customer does purchase sufficient flood insurance before the end of the forty-five days, the law would not permit the bank to recoup the costs of force-placed flood insurance that was in place at the same time as the customer’s flood insurance. 42 USC 4012a(e)(3).