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All in Flood
In this Compliance Clip (video), Adam explains what can be done when a structure is located in a high-risk flood zone, but a customer doesn’t want to get flood insurance because the building is old, unusable, or wouldn’t be replaced if it was damaged. This is a great video to share with your lending team who may ask this question from time to time.
In this Compliance Clip (video), Adam discusses what lenders must do if there is a discrepancy between the flood determination and the declaration page. While the industry has long understood one answer to this question, the May 2022 Flood Q&A’s made some significant changes to what is expected when there is a discrepancy between the declaration page and flood determination. Therefore, Adam discusses the applicable Flood Q&A’s as well as how FEMA 2.0 has impacted the answer to this question.
In this Compliance Clip (video), Adam discusses the changes that are included in the May 2022 Interagency Questions and Answers Regarding Flood Insurance. Of course, there were many different changes as these revisions are the first in over a decade that saw many law and rule changes related to flood insurance.
On May 11, 2022, five federal regulatory agencies jointly issued revised questions and answers (Q&As) regarding federal flood insurance law and the agencies’ implementing regulations. The Q&As supersede those originally published by the agencies in 2009 and 2011 as well as consolidate Q&As proposed by the agencies in 2020 and 2021. The revised Q&As also include the changes to the flood insurance requirements made by federal law in recent years. We plan to release a training program coving the Flood FAQs during the summer of 2022, so contact us with more information regarding this future program.
In this Compliance Clip, Adam gives valuable insights on what to do when there is a discrepancy between appraisal and flood determination forms. In particular, this video uses the example of a commercial building in multiple structures wherein the flood determination says that the structures are not in a high risk flood zone while based on the appraisal, one of the structures is in a high-risk flood zone. A transcript of this video is now available.
In this 3rd annual Halloween version of our Compliance Clips (video), Adam discusses Flood Insurance Manual changes that affect the flood zone listed on the declaration page of a flood insurance policy. This video is sure to make a splash with your lending team, so let’s dive right in.
On 3/11/21, several Federal agencies jointly issued a request for comment on 24 proposed Interagency Questions and Answers Regarding Private Flood Insurance. In their joint release, the agency explain that the proposal is intended to help lenders comply with the 2019 rule which implemented the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012.
On 11/23/2020, HUD issued a proposed rule that would amend Federal Housing Administration (FHA) regulations to allow mortgagors the option to purchase private flood insurance on FHA-insured mortgages for properties located in Special Flood Hazard Areas (SFHAs), in satisfaction of the mandatory purchase requirement of the Flood Disaster Protection Act of 1973 (the FDPA).
On 10/1/2020, President Trump signed H.R.8337 which extends the National Flood Insurance Program (NFIP) through September 30, 2021. While funding for the flood program, and other government programs, expired for about an hour after the September 30, 2020 deadline had passed, CNBC reports that President Trump signed the bill early Thursday after apparently getting back from a campaign trip to Minnesota. While the bill only extends many government functions through December 31, 2020, it does specifically extend the NFIP through September 30, 2021.
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.
