What insurance should a CRE lender require and keep on file?
The OCC's Commercial Real Estate Lending handbook lists what a loan file typically holds, including "insurance policies, and proof of premium payment that show the bank's interest is adequately protected against hazard, liability, and, when appropriate, loss of rents and flood." For construction loans the same list adds "builder's risk insurance."
The handbook treats this as ongoing work, not a closing item. It warns that "A bank's failure to confirm that property taxes, property insurance premiums, and workers and suppliers are paid can threaten its collateral interests," and notes that loan policies "typically establish underwriting standards pertaining to appropriate owner equity (e.g., LTV), acceptable appraisal or valuation methods, insurance requirements, and ongoing collateral monitoring."
In practice the requirements live in each loan agreement: coverage types, minimum limits, maximum deductibles, the named insured, the lender clauses and any insurer rating minimum. Those terms are often negotiated, so two loans in the same portfolio can require different things.
How does CoverCheck monitor insurance compliance?
CoverCheck runs on the MightyBot platform. It reads the insurance section of each loan agreement and builds a requirement list for that loan, filling gaps from your written insurance standards. Those standards are plain-English policies your team can edit.
Every certificate of liability insurance, evidence of property insurance, declaration page and endorsement the borrower sends is matched to its loan and read on arrival. Coverages, limits, deductibles, dates, the named insured and the mortgagee, loss payee and additional insured wording are extracted with their source pages and tested against the loan’s requirements.
Each loan keeps a status of compliant, deficient, expiring or lapsed, and the portfolio gets a lapse calendar. Renewal requests go to the borrower or agent before each expiration, listing what the new documents must show. Deficiencies go to your team with the evidence attached.
What do the flood rules add?
For FDIC-supervised institutions, 12 CFR 339.3 says a designated loan cannot be made, increased, extended or renewed unless the building "is covered by flood insurance for the term of the loan," and that "The amount of insurance must be at least equal to the lesser of the outstanding principal balance of the designated loan or the maximum limit of coverage available for the particular type of property under the Act."
Those maximums are set in 44 CFR 61.6. Under the regular program, the table lists $500,000 of building coverage for a "Non-Residential Building" and for an "Other Residential Building (including Multifamily Building)." A loan agreement can require more through private or excess flood coverage.
The monitoring duty runs for the life of the loan. Under 12 CFR 339.7, if the institution or its servicer "determines at any time during the term of a designated loan" that coverage is missing or short, it "shall notify the borrower," and "If the borrower fails to obtain flood insurance within 45 days after notification, then the FDIC-supervised institution or its servicer shall purchase insurance on the borrower's behalf." CoverCheck finds the gap and drafts the borrower notice; the 45 days run from the date your team or servicer sends it, and placing coverage stays with you.