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, both of which resulted in significant revisions to the Agencies’ flood regulations.
The author has complained at every possible moment for the last nine years about the lack of guidance on flood matters from the Agencies. The updates include, but are not limited to, the detached structure exemption, escrow requirements, and force-placement rules.
The comment period ends 60 days after publication in the Federal Register, which is expected soon.