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INTERAGENCY FLOOD FAQS

On June 26, 2020 the Federal Reserve Board, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration (collectively the Agencies) released proposed new and revised Interagency Questions and Answers Regarding Flood Insurance (FAQs). The FAQs have not been updated since 2011, which is gross incompetence on the part of the Agencies. Since the last revisions Congress has passed the Biggert-Waters Act and the Affordability Act, […]

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UPDATED FLOOD INSURANCE EXAMINATION PROCEDURES

Recently the OCC, the FRB, the FDIC, the FCA, and the NCUA, through the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council, revised the Interagency Examination Procedures for the Flood Disaster Protection Act. The revised procedures reflect the February 2019 final interagency rule that addresses the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012. The updated procedures incorporate new sections that discuss: Mandatory acceptance of a […]

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PROPOSED FEMA FLOOD REGULATIONS

On July 16, 2018 the Federal Emergency Management Agency (FEMA) proposed revisions to its flood regulations. FEMA proposes to amend parts 59, 61, and 62 of 44 CFR. These parts contain regulations implementing the NFIP. In addition, FEMA proposes to amend Appendices A(1) – A(3) of part 61, containing the three forms of the SFIP: The Dwelling Policy Form, the General Property Form, and the Residential Condominium Building Association Form. FEMA proposes this rulemaking for […]

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AGENCIES PROPOSE PRIVATE FLOOD INSURANCE RULES

The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), the Farm Credit Administration (FCA), and the National Credit Union Administration (NCUA) have issued a new proposal to amend their regulations regarding loans in areas having special flood hazards to implement the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert-Waters Act). The proposed rule […]

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LOGIC BEHIND THE SMALL BANK FLOOD ESCROW EXEMPTION

We discussed the issue of the small bank exemption from the new flood insurance escrow requirements in previous articles entitled Flood Rule Conundrum and Flood Rule Conundrum – Part II. We almost called this one Flood Rule Conundrum – Part III, but we thought that would be too repetitious too repetitious. The issue is whether a small bank, that had previously escrowed for Higher-Priced Mortgage Loans (HPML), could be eligible for the new exemption from […]

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