On October 1, 2025, the federal agencies issued a reminder to lenders that they may continue to make loans that are subject to the federal flood insurance statutes when the National Flood Insurance Program is not available.

As outlined in the Interagency Questions and Answers Regarding Flood Insurance (Q&A Applicability 12), lenders may continue making loans secured by properties in Special Flood Hazard Areas (SFHAs) during an NFIP lapse. However, they must still perform flood zone determinations, provide timely and accurate borrower notices, and comply with all other applicable flood insurance requirements. The reminder also encourages lenders to carefully consider any legal or safety and soundness risks that may arise and to prudently manage those risks throughout the lapse.

Read the OCC’s news release here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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