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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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Flood Insurance Revisions – Completing the Journey Webinar

WHAT? The recent round of Flood Insurance rule changes are nearly complete. The next round is on the horizon. 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 […]

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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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JOINT AGENCIES ISSUE FINAL RULE ON FLOOD INSURANCE

The joint agencies (OCC, Federal Reserve Board, FDIC, Farm Credit Administration and NCUA) recently approved a final rule that modifies the regulation for loans secured by property located in a special flood hazard area.  The final rule implements certain provisions that were established under the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) such as the requirement to escrow for flood insurance premiums on residential improved real estate securing a loan, as well as, an […]

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PROPOSED FLOOD INSURANCE REGULATIONS

The Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board), Federal Deposit Insurance Corporation (FDIC), the Farm Credit Administration (FCA), and the National Credit Union Administration (NCUA) (collectively, the Agencies) are proposing to amend their flood insurance regulations to implement certain provisions of the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA), which amends some of the changes to the Flood Disaster Protection Act of 1973 mandated […]

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