Proof of Insurance and EOI for Lenders

What "evidence of insurance" means

Evidence of insurance (EOI) is any document a lender relies on to confirm the collateral is insured as the loan requires: before closing, and for the life of the loan as the servicer tracks renewals. For the clause the evidence must display, see what a mortgagee clause is.

Common types of proof

Declarations page

The declarations page (dec page) summarizes the named insureds, property address, policy period, coverages and limits, deductibles, premium, and the mortgagee(s). Because it comes from the policy itself, many lenders treat it as the primary proof for homeowners and dwelling policies. A federal rule recognizes it too: the CFPB's official commentary to Regulation X's force-placed insurance rule (12 CFR 1024.37) says a servicer may require "a copy of the borrower's hazard insurance policy declaration page, the borrower's insurance certificate, the borrower's insurance policy, or other similar forms of written confirmation."

ACORD 27, Evidence of Property Insurance

ACORD's instructions describe ACORD 27 as providing a coverage statement for mortgagees and loss payees on residential property, personal property, or small commercial properties. If the lender or settlement agent needs to pay the premium, send an invoice with the form.

ACORD 28, Evidence of Commercial Property Insurance

ACORD 28 is for real property or business personal property insured under a commercial lines policy where the lender needs more detail. The current form includes fields for items such as business income or rental value, blanket coverage, coinsurance, ordinance or law, equipment breakdown, flood, earth movement, wind/hail and named storm, and terrorism.

Important limitation of ACORD forms

The 2016 editions of ACORD 27 and ACORD 28 both state that they are issued as a matter of information only and confer no rights upon the additional interest named, and that they do not amend, extend, or alter the policy coverage. The rights come from the policy and its endorsements, which is why commercial lenders often ask for the endorsements too.

Full policy, certificates, and electronic data

Fannie Mae's Selling Guide (B7-3-07) says a lender or servicer may accept a certificate of property insurance in place of the complete policy if it includes all the information needed to confirm the coverage meets Fannie Mae's requirements, and that the certificate must be signed by the insurer. It also allows electronic data files in place of hard-copy policies when specified conditions are met, which is part of why many servicers receive policy data electronically from insurers.

Some states regulate certificate forms. The Texas Department of Insurance publishes a list of approved property and casualty certificates that includes ACORD 27 and ACORD 28 editions, and New York's Department of Financial Services posts approved ACORD 27 and 28 forms. Use current approved editions and do not alter form text.

What to include

A complete submission to a lender usually contains:

1. Named insured(s) matching the people on title. Fannie Mae requires all title holders to be named insureds on one- to four-unit policies.
2. Property address exactly matching the loan file, including unit number.
3. Mortgagee clause with the lender's or servicer's exact name, successor language, insurance address, and loan number.
4. Policy number, carrier, and policy period (effective and expiration dates).
5. Coverage limits and deductibles, including separate wind, hurricane, or named storm deductibles if any.
6. Premium and payment status, usually via an invoice or paid receipt if the lender is paying from escrow or at closing.

Sending proof to the lender or servicer

Before closing

Send evidence to the processor, closer, or the lender's designated insurance contact, with time for review. Title and escrow staff usually need the premium invoice to disburse payment. Confirm that the effective date is on or before the closing or funding date.

After closing: the servicer's insurance address or portal

Once the loan boards with a servicer, insurance documents go to its designated insurance address or, where the servicer offers one, an online submission or verification portal. Some servicers use outside insurance tracking providers to receive and match documents. These channels are separate from the payment address, and a dec page sent to a payment lockbox may never be matched to the loan.

Fannie Mae also requires the insurer to be instructed to send policies, bills, and correspondence to the servicer, so a correct mortgagee clause means renewals reach the servicer automatically.

Members can find a lender's or servicer's insurance clause and address on its mortgageeclauses.com lender page via search. Each listing is marked Verified (confirmed against the lender's or servicer's own primary source, with the date checked) or Pending Verification.

When the servicer says it has no proof

A servicer that lacks evidence of coverage may move toward force-placed (lender-placed) insurance, which Regulation X tightly regulates:

• The servicer must have a reasonable basis to believe the borrower failed to maintain required hazard insurance before charging for force-placed coverage.
• It must send a first written notice at least 45 days before charging, and a reminder notice at least 15 days before charging, no earlier than 30 days after the first notice.
• The servicer may reject evidence if neither the insurer nor the agent confirms the information the borrower submitted. Agent or carrier confirmation therefore carries real weight.
• Within 15 days of receiving evidence of continuous compliant coverage, the servicer must cancel the force-placed policy and refund premiums and fees for any overlap period.
• For borrowers with escrow accounts, 12 CFR 1024.17(k)(5) generally bars a servicer from force-placing coverage unless it is unable to disburse escrow funds to pay the premium on time; insufficient escrow funds alone do not count as being unable, and a limited exception exists for certain small servicers.

Practical response: send the dec page or EOI with the loan number to the servicer's insurance channel and keep proof of delivery. If a policy was reinstated without a gap, show the reinstatement.

Servicing transfers

After a transfer, the borrower may receive insurance requests from the new servicer. Fannie Mae's Servicing Guide (F-1-11) requires servicers to ask insurers to substitute the new servicer in the mortgagee clause and update billing, and to pass along policy expiration dates and premium frequencies. When an agent receives the request, update the mortgagee (see how to add or change a mortgagee) and issue fresh evidence to the new servicer.

Common mistakes

• Sending evidence with the prior lender's clause after a refinance or transfer.
• Omitting the loan number, so the document cannot be matched.
• Mailing proof to the payment address.
• Altering ACORD form wording or using outdated editions.
• Relying on an ACORD form alone on a commercial loan whose documents require specific endorsements.
• Omitting separate wind or named storm deductibles.

Frequently asked questions

Is a declarations page proof of insurance?

Yes, for most lenders and servicers. The CFPB's Regulation X commentary lists the declaration page, an insurance certificate, the policy, or similar written confirmation as evidence a servicer may require. Lenders can set additional requirements, such as a paid receipt.

What is the difference between ACORD 27 and ACORD 28?

ACORD 27 is the Evidence of Property Insurance form used for residential property, personal property, or small commercial properties. ACORD 28 is the Evidence of Commercial Property Insurance form, used for commercial lines property when the lender needs more detail on coverages, deductibles, and conditions.

Does an ACORD 27 or ACORD 28 give the lender rights?

No. The 2016 editions state they are issued as a matter of information only and confer no rights on the additional interest named. The lender's rights come from the mortgage clause, loss payable provisions, or endorsements on the policy itself.

Where should I send proof of insurance after closing?

Send it to the servicer's designated insurance address or submission portal, not the mortgage payment address, and include the loan number. Members can find current insurance addresses on lender pages at mortgageeclauses.com.

Why did the borrower get a force-placed insurance letter when the policy is active?

Usually because the servicer has not matched current evidence to the loan, often due to a wrong mortgagee clause, missing loan number, or a recent servicing transfer. Regulation X requires the servicer to cancel force-placed coverage and refund overlapping charges within 15 days of receiving evidence of continuous compliant coverage.

Related resources

Clause wording is covered in ISAOA and ATIMA explained, role differences in loss payee vs. mortgagee vs. additional insured, and state-level rules in requirements by state and the state pages. See also the glossary, pricing, and for insurance agents.

Sources

• Fannie Mae Selling Guide B7-3-07, Evidence of Property Insurance: https://selling-guide.fanniemae.com/sel/b7-3-07/evidence-property-insurance
• Fannie Mae Selling Guide B7-3-08, Mortgagee Clause, Named Insured, and Notice of Cancellation Requirements: https://selling-guide.fanniemae.com/sel/b7-3-08/mortgagee-clause-named-insured-and-notice-cancellation-requirements
• Fannie Mae Servicing Guide F-1-11, Post-Delivery Servicing Transfers: https://servicing-guide.fanniemae.com/svc/f-1-11/post-delivery-servicing-transfers
• CFPB, Regulation X, 12 CFR 1024.37, Force-placed insurance (with official interpretations): https://www.consumerfinance.gov/rules-policy/regulations/1024/37/
• CFPB, Regulation X, 12 CFR 1024.17, Escrow accounts (paragraph (k), timely payments): https://www.consumerfinance.gov/rules-policy/regulations/1024/17/
• ACORD 27 form instructions (copy hosted by HawkSoft user group): https://hawksoftusergroup.org/wp-content/uploads/2021/09/ACORD-27-Instructions-002-1.pdf
• ACORD 27, Evidence of Property Insurance (2016/03), New York DFS approved form: https://www.dfs.ny.gov/system/files/documents/2021/02/acord_27_2016-03.pdf
• ACORD 28, Evidence of Commercial Property Insurance (2016/03), New York DFS approved form: https://www.dfs.ny.gov/system/files/documents/2021/02/acord_28_2016-03.pdf
• Texas Department of Insurance, Property and Casualty Certificates of Insurance: https://tdi.texas.gov/certificates/