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All in Flood
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.
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
