TopMortgage Compliance Update (1)

October 18, 2011


FRB: Issues Flood Insurance FAQs and Proposed Revisions

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The federal agencies that supervise banks, thrifts, and credit unions, and the Farm Credit System, on October 14, 2011 announced that it published guidance that updates the Interagency Questions and Answers Regarding Flood Insurance that were most recently published on July 21, 2009 (see 74 FR 35914-35947).

On October 17, 2011, the Federal Register published the guidance concerning the Loans in Areas Having Special Flood Hazards, Interagency Questions and Answers Regarding Flood Insurance.

The federal agencies participating in this guidance are the Office of the Comptroller of the Currency, Treasury (OCC), Board of Governors of the Federal Reserve System (Board), Federal Deposit Insurance Corporation (FDIC), Farm Credit Administration (FCA), and the National Credit Union Administration (NCUA), (collectively, the Agencies).

The guidance finalizes two questions and answers that had been previously proposed. The first relates to insurable value. The second relates to force placement of flood insurance. The Agencies withdrew another question regarding insurable value.

The two final questions and answers supplement the Interagency Questions and Answers Regarding Flood Insurance (Interagency Questions and Answers), which were published on July 21, 2009 (74 FR 35914).
  • Effective Date - Final questions and answers: October 17, 2011.
  • Effective Date for Comments: December 1, 2011. 
It is the intention of the Agencies that, after public comment has been received and considered and the guidance has been adopted in final form, the Agencies will issue a final update to the 2009 Interagency Questions and Answers Regarding Flood Insurance. The final update will continue to supplement other guidance or interpretations issued by the Agencies and the Federal Emergency Management Agency.

The Agencies request comment on three additional proposed updates to questions and answers relating to force placement of flood insurance. Two answers have been significantly and substantively changed. The third change, regarding force placement of flood insurance, revises a previously finalized Question and Answer for consistency with the proposed changes.

The Agencies are requesting comment on the proposed changes to the Interagency Questions and Answers Regarding Flood Insurance and, more generally, on other issues and concerns regarding compliance with the federal flood insurance statutes and regulations. Comments are due 45 days after publication in the Federal Register.

Based on comments received, the Agencies also have significantly revised two questions and answers regarding force placement of flood insurance that were initially proposed on July 21, 2009, and are now proposing revision to a previously finalized question and answer. These three revised questions and answers are being proposed for comment.
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    Federal Reserve System - Interagency     


Loans in Areas Having Special Flood Hazards
Interagency Questions and Answers Regarding Flood  


Federal Register - 76/200


October 17, 2011



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