All in Flood
On 9/1/2020, the five joint regulatory agencies announced that they extended the comment period to revise the Interagency Questions and Answers Regarding Flood Insurance (Interagency Questions and Answers) until November 3, 2020.
In their release, the agencies explain that they extended the comment period because of the extent of the revisions proposed by the agencies and in light of the challenges associated with the COVID-19 pandemic.
On 7/20/2020, FEMA published a final rule in the Federal Register updating the National Flood Insurance Program rules. This release is the final rule from FEMA’s 7/16/2018 Notice of Proposed Rulemaking that proposed to make several non-substantive changes to the flood program regulations to improve their readability, uniformity, and clarity. In addition, FEMA planned to include certain requirements of the Biggert-Waters Flood Insurance Reform Act of 2012 and the Homeowner Flood Insurance Affordability Act of 2014.
On 6/26/2020, the OCC, Federal Reserve, FDIC, Farm Credit Administration, and the NCUA issued a joint proposal to update the interagency flood FAQs. If issued as proposed, these revisions would be the first updates to the Interagency Questions and Answer Regarding Flood Insurance since they were last updated in 2011.
As you might recall, there have been several updates to flood insurance rules since 2011 including the Biggert-Waters Flood Insurance Reform Act of 2012, the Homeowner Flood Insurance Affordability Act of 2014, interagency guidance on the detached structure exemption, rules on the escrow of flood insurance premiums, and private flood insurance guidance. In addition to updating the questions and answers to align with most of the current flood insurance laws and guidance, the proposal would also…
On May 6, 2020, the Federal Reserve released a letter to all state member banks supervised by the Federal Reserve titled “Flood Insurance Compliance in Response to the Coronavirus.” In their release, the Fed explains that they have received questions from state member banks regarding flood insurance compliance requirements during the national emergency due to the COVID-19 outbreak (COVID-19 emergency). This letter provides two flood insurance questions and answers to assist state member banks in their efforts to meet the financial needs of their customers.
On 11/19/19, the House Committee on Appropriations released a statement that the House passed a continuing resolution to extend federal government funding through December 20, 2019, which includes an extension of the National Flood Insurance Program (NFIP). This is the fourteenth temporary extension since 2017 while lawmakers work on a longer-term solution that would
As has been the case over a dozen times in the last few years, the National Flood Insurance Program’s (NFIP’s) short-term extension is set to expire unless Congress either establishes a long-term fix or just kicks the can down the road again by implementing another short-term extension. Either way, financial institutions will once again want to be prepared in the event the NFIP does lapse. The current NFIP extension is set to expire at midnight on Thursday, November 21, 2019. For information on what to do in the event of a lapse, you can…
During the end of September, Congress extended the National Flood Insurance Program for another few months, through November 21, 2019. As the NFIP was set to expire at the end of day on September 30, 2019, this new extension marks the thirteenth temporary extension of the flood program within the last few years. As we have noted before, this large number of temporary extensions signal a desire by Congress to make long-term changes to the program. In fact, Congress has been working on a bipartisan 5 year extension, but have yet to come to an agreement on what that extension would look like. As you have already probably noted, these continued short term extensions are…
In this Compliance Clip (video), Adam answers the question of “what is the compliance aid for flood insurance?” To answer this question, Adam explains what the compliance aid is, how it is used, and what to watch out for. For those looking for more information on the 2019 Private Flood Insurance rules, check out the curriculum of our program on the 2019 Private Flood Insurance Final Rule here.
As the twelth exetension of the National Flood Insurance Program is set to expire on September 30, 2019, financial institutions must again hold their breath (no pun intended) to see if Congress yet again kicks the can down the road by renewing the program one more time. While we at the Compliance Cohort will be sure to keep you up-to-date with any changes to the Flood program, you may be wondering what you should do if the Flood program does, in fact, expire. Check out this article for guidance on what your financial institution should do if the flood program were to expire: https://www.compliancecohort.com/blog/what-to-do-if-the-nfip-expires
The Federal Financial Institutions Examination Council recently (8/22/19) updated their Flood Exam manual to reflect the new requirements for mandatory acceptance of private flood insurance. Mandatory acceptance of private flood insurance was mandatory in July of 2019. If your organization is looking for more information on this now required rule, be sure to take a look at our premium course on private flood insurance at https://www.compliancecohort.com/video-webinar-private-flood-insurance-2019-final-rule. Read more on this article to get a link to the updated exam procedures.
