It has been over seven weeks since the Agencies (FRB, OCC, FDIC, NCUA, and FCA) issued a joint final rule to modify existing flood regulations. And until this week the Agencies had inconsistent opinions about how the small lender escrow exception will apply to lenders that were required to escrow under Regulation Z’s Higher Priced Mortgage Loan (HPML) rules. This week we learned some good news – it appears we now have a consensus among […]
Category: Biggert-Waters
FLOOD RULE CONUNDRUM: DOES YOUR FINANCIAL INSTITUTION QUALIFY FOR THE SMALL LENDER EXCEPTION?
On June 22nd, the agencies (FRB, OCC, FDIC, NCUA, and FCA) issued a joint final rule to modify existing flood regulations. On June 24th, we issued an article discussing these new interagency flood rules (to access that article click here) that examined the three main elements of the final rule: detached structures, escrow provisions, and force placement. Since then we have received numerous questions relating to the small lender exception to the escrow portion of […]
JOINT AGENCIES ISSUE FINAL RULE ON FLOOD INSURANCE
The joint agencies (OCC, Federal Reserve Board, FDIC, Farm Credit Administration and NCUA) recently approved a final rule that modifies the regulation for loans secured by property located in a special flood hazard area. The final rule implements certain provisions that were established under the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) such as the requirement to escrow for flood insurance premiums on residential improved real estate securing a loan, as well as, an […]