Archive

WILL FLOOD INSURANCE EXPIRE ON SEPTEMBER 30TH?

Congress is debating whether to extend the National Flood Insurance Program, which expires on September 30. Since 2017 Congress has often waited (12 times) until the last minute to reauthorized the program before its expiration and passed only short-term extensions. Last week, the U.S. House of Representatives passed H.R. 4378 to keep the federal government funded through November 21 and included an extension for the NFIP through the same date. The resolution is on the Senate […]

BOARD CONSIDERATION OF MUTUAL AID SOCIETY PLANS

The February 2019 revision to the flood insurance regulations provides a definition of a “mutual aid society” and describes the conditions under which a regulated lending institution may accept a flood protection plan issued by a mutual aid society. Within the Board’s Regulation H, 12 CFR 208.25(c)(3)(iv) enumerates those conditions. The first of the conditions for acceptability of a mutual aid plan requires that “the Board has determined that such plans qualify as flood insurance […]

UPDATED FLOOD INSURANCE EXAMINATION PROCEDURES

Recently the OCC, the FRB, the FDIC, the FCA, and the NCUA, through the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council, revised the Interagency Examination Procedures for the Flood Disaster Protection Act. The revised procedures reflect the February 2019 final interagency rule that addresses the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012. The updated procedures incorporate new sections that discuss: Mandatory acceptance of a […]

REGULATORY DEADLINE REMINDERS

July 1, 2019 is the effective date for two major compliance events. This is a reminder that some of you have a lot of work to complete in the next 20 business days. Mandatory Acceptance of Private Flood Insurance – Starting on Monday July 1, 2019 all financial institutions must be in compliance with the new Mandatory Purchase Requirements for Private Flood Insurance. By that date your policy and procedures must be updated and your […]

FLOOD INSURANCE EXTENSION

On May 30 S. 1693 passed in the House, after previously passing in the Senate, and moved to the president for signature. The bill’s sole function is to extend funding for the National Flood Insurance Program from May 31, 2019 to June 14, 2019.