The Federal Civil Penalties Inflation Adjustment Act of 1990 (FCPIA Act)requires Federal agencies to adjust, by regulation, the Civil Monetary Penalties (CMPs) within their jurisdiction by a prescribed inflation adjustment at least once every four years. The Federal Reserve Board (FRB) made its last adjustment to its CMPs on October 6, 2008, On November 16, 2012 the FRB issued a final rule to set forth the newly-adjusted CMPs which will apply to violations that occur […]
Category: Flood Insurance
MAJOR FLOOD INSURANCE REVISIONS SIGNED INTO LAW
On July 6, 2012, President Obama signed into law the Moving Ahead for Progress in the 21st Century Act (Map-21) (H.R. 4348), which , includes the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert-Waters). Among numerous other provisions, Biggert-Waters re-authorizes the National Flood Insurance Program (NFIP) through 2017. The NFIP had been operating under stopgap extensions (18 since 2008) and shut down twice for several weeks. Just one of these lapses, in June 2010, stalled […]
FINALLY – REVISED STANDARD FLOOD HAZARD DETERMINATION FORM
The Standard Flood Hazard Determination Form (SFHDF) is used by Federally regulated lending institutions when making, increasing, extending, renewing or purchasing a loan for the purpose of determining whether flood insurance is required and available. The form is required by Section 303 (a) of Title V of the National Flood Insurance Reform Act of 1994 (NFIRA). The FEMA Form number for the Standard Flood Hazard Determination Form (SFHDF) has been changed from FEMA Form 81-93 […]
THE FLOOD INSURANCE MERRY-GO-ROUND CONTINUES
On May 30th the President signed HR 5740, extending the NFIP’s authority for an additional 60 days. The law enables FEMA to enter into flood insurance contracts through July 31, 2012. For the past several years Congress has played this funding game. The flood laws need some serious attention. Congress cannot agree on the steps needed to improve the program. So rather than approve long-term funding for the insurance program a series of short-term funding […]
RENEWING LOANS WITH FORCE PLACED INSURANCE
“Can we renew a loan which is covered by force placed insurance?” Variations on this question have come up several times in recent seminars I have conducted. The answer to the question is no. If a borrower refuses to obtain flood insurance coverage as a condition of obtaining a loan, the loan is deficient and may not be made. Force placement of coverage is designed for use at any time during the loan in uninsured […]