The regulatory requirements for private flood insurance have been undergoing change since Congress passed and the President signed the Biggert-Waters Flood Insurance Reform Act (Biggert-Waters Act) in 2012. Finally, the almost seven-year journey is complete. During January 2019 the Comptroller of the Currency, the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Farm Credit Administration (the Agencies) published a final rule implementing the private flood insurance rules, effective July 1, 2019.
Every financial institution must adapt their policies and procedures for the new rules. The potential civil monetary penalties for non-compliance with the revisions are substantial. The final rule differs dramatically from the previous regulatory guidance and from the 2016 proposed rule.
This program explains the new final rules for private flood insurance, explores the options for compliance and provides suggestions for successful implementation of the requirements.
Participants receive a detailed manual that serves as a handbook long after the program is completed.
Upon completion of this program, participants understand:
- The new final private flood insurance rules;
- When private flood insurance must be accepted and when it may be accepted, including "discretionary acceptance;"
- How to identify a policy as a private flood policy instead of a FEMA policy;
- How the Compliance Aid works;
- The process for verifying and documenting the presence and acceptability of the Compliance Aid statement;
- Issues related to the side-by-side policy review including:
- When is a side-by-side review required;
- Who should conduct the review; and
- How to conduct and document the review;
- The issues related to having a third party conduct the side-by-side review;
- The issues related to passing the cost of the side-by-side review, whether conducted by the creditor or by a third-party, on to the consumer
- What is a mutual aid society and when can coverage from such a group be accepted;
- The content of acceptable policies and procedures for implementing the new rules;
- How to train appropriate staff to comply with the new requirements; and
- The potential penalties for not complying with the new requirements.
The program is designed for loan officers, compliance officers, loan processors and clerks and auditors.
Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 43 years. In 38 years as a trainer over 145,000 bankers (and many examiners) have participated in Jack’s live seminars and webinars. Jack’s career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by a number of state bankers associations. As a contractor he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association.
Robin Cooper, CRCM is the Director of Compliance for Compliance Resource, LLC, a source of compliance assistance for financial institutions. Robin’s career in banking began in 2004. Since that time she has worked for community and regional financial institutions ranging from $100 million to $1 billion in asset size regulated by the Office of the Comptroller of the Currency (OCC) and Federal Reserve Board (FRB). Robin has worked in numerous compliance and banking roles, including Compliance Auditor, Internal Auditor, BSA Officer, and Compliance Officer. In 2010 Robin established and led the, now longstanding, Central Kentucky compliance roundtable for compliance officers in central and southern Kentucky to convene and discuss emerging compliance issues. Robin has a bachelor’s degree in Government from Centre College, attended the American Bankers Association National Compliance School, and is a Certified Regulatory Compliance Manager.