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It took Congress and the financial institution regulatory agencies 14 years to development and implement the law and regulations for mandatory acceptance of private flood insurance. 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. 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. That rule was effective July 1, 2019.
Every financial institution needed to revise existing policies and procedures for the new rules. The potential civil monetary penalties for non-compliance with the revisions are substantial.
This recording revisits the final rules for private flood insurance, explores the options for compliance and provides suggestions for successful implementation of the requirements.
You’ll receive a detailed manual that serves as a handbook long after the program is completed.
Upon completion of this recording, you’ll understand:
- The 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 final rule;
- How to train appropriate staff to comply with the requirements; and
- The potential penalties for not complying with the requirements.
The recording is designed for loan officers, compliance officers, loan processors and clerks and auditors.