Flood Insurance rules are in turmoil. On July 6, 2012 Congress passed the Biggert-Waters Flood Insurance Reform Act (Biggert-Waters). On March 23, 2014 Congress passed the Homeowner Flood Insurance Affordability Act (Affordability Act). The Affordability Act revises certain sections of Biggert-Waters, eliminates or delays other sections and creates new rules.
Since 2012 FEMA and the financial institution regulatory agencies (OCC, Federal Reserve Board, FDIC, Farm Credit Administration and NCUA) have been working on regulations to implement the numerous changes. The interagency final rules were published in late June.
The final rule implements certain provisions that were established under the Affordability Act such as the requirement to escrow for flood insurance premiums on residential improved real estate securing a loan, as well as, an exemption for mandatory flood insurance for specific detached structures. In addition to the requirements established by the Affordability Act, the final rule implements provisions of the Biggert-Waters regarding the force placement of flood insurance. The final rule was generally effective as of October 1, 2015, but the escrow requirement for flood insurance payments were effective January 1, 2016.
The Flood Insurance Review and Update training manual explains the new laws and final regulations, and also provides a thorough review of the traditional flood insurance requirements.
Compliance Resource training manuals are designed to be used when conducting in-house training, whether initial training upon implementation of the new requirement, periodic training for new team members or remedial training for longer-term team members.