During one of our February 16, 2018 CMG meetings regarding Private Flood Insurance we received an interesting comment and an insightful question. Comment – The comment, submitted privately, stated, ” I just wanted to let you all know that I just finished my compliance exam and we had to write memos for the loan files explaining that have reviewed and determined that our customers with higher flood deductibles are able to afford them.” While I […]
Category: Flood Insurance
AGENCIES PROPOSE PRIVATE FLOOD INSURANCE RULES
The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), the Farm Credit Administration (FCA), and the National Credit Union Administration (NCUA) have issued a new proposal to amend their regulations regarding loans in areas having special flood hazards to implement the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert-Waters Act). The proposed rule […]
NEW FLOOD HAZARD DETERMINATION FORM
On July 27, 2016 FEMA made available on its website an updated Flood Hazard Determination Form (SFHDF). The SFHDF is required for all federally backed loans and is used by lenders to determine the flood risk for their building loans. The previous form which expired on May 30, 2015 can continue to be used during the phase in period of the new form. The phase-in period has not been detailed at this time. The new form […]
LOGIC BEHIND THE SMALL BANK FLOOD ESCROW EXEMPTION
We discussed the issue of the small bank exemption from the new flood insurance escrow requirements in previous articles entitled Flood Rule Conundrum and Flood Rule Conundrum – Part II. We almost called this one Flood Rule Conundrum – Part III, but we thought that would be too repetitious too repetitious. The issue is whether a small bank, that had previously escrowed for Higher-Priced Mortgage Loans (HPML), could be eligible for the new exemption from […]
FLOOD RULE CONUNDRUM PART II: CONSENSUS AMONG AGENCIES ON SMALL LENDER EXCEPTION
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 […]