Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.
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All in Flood
In this Compliance Clip (video), Adam explores whether lenders can reuse a previous flood determination when refinancing or assuming a loan, or when multiple loans are secured by the same property. He discusses why the answer isn’t always as straightforward as it may seem and highlights the regulatory guidance lenders need to consider before relying on an existing determination. A transcript of this video is now available.
In this Compliance Clip (video), Adam explores an important question about the timing of the flood notice when a loan involves property located in a high-risk flood zone. He discusses what lenders should consider when determining how far in advance the notice should be provided and highlights guidance that can help lenders avoid potential compliance issues. A transcript of this video is now available.
In this Compliance Clip (video), Adam discusses what effective flood compliance training for a Board of Directors should include and why finding the right level of detail can be challenging. He explains the unique role Directors play in overseeing flood compliance and the importance of providing training that is meaningful without overwhelming them with regulatory details. A transcript of this video is now available.
In this Compliance Clip (video), Adam explains the key events that trigger a financial institution's flood insurance compliance requirements. Learn when flood rules apply and why understanding these compliance triggers is essential for ensuring your institution meets its regulatory obligations. A transcript of this video is now available.
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.
In this Compliance Clip (video), Adam explores the topic of flood insurance as it relates to buildings with limited utility or value, focusing on a case involving a construction-to-permanent loan. Using insights from interagency guidelines, Adam clarifies the insurance requirements for properties in flood-prone areas, even when the structures may not hold significant value.
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.
