[rcooper]

Information/comment we received from one of our members:

We contacted our regulator (FDIC) after the conference call on the HO Flood Insurance Affordability Act. At the time, he did not have any guidance on the effective date of the above Act [detached structures].

He called this week and said that the examiners had received guidance that the change impacting detached structures went into effect when it was signed in March. I asked him what type of documentation would be required to evidence that the structure was not being utilized for living quarters. He said the guidance did not go that far into detail. Our examiner indicated he would be flexible and rely on the documentation in file, as long as it was reasonable.

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