Description
Flood compliance is complicated! The rules themselves are complex, and the details of each situation bring a torrent of different requirements to get right. The spectrum of issues is massive! Plus, much is at stake – floods cause catastrophic damage, taking a toll on your borrower’s property, your collateral, and your compliance program.
The regulatory agencies, recognizing how broad and complex these issues are, began in 1997 to issue Interagency Q&As on the technical requirements of Federal flood insurance laws. Over the years, the Interagency Q&A have been amended, expanded and updated, with 2022 bringing the most significant updates yet.
The 2022 FAQs address major developments that occurred in the flood world since the prior 2011 update. Not only was there the Biggert-Waters Flood Insurance Reform Act of 2012 and the Homeowner Flood Insurance Affordability Act of 2014, but then FEMA rolled out Risk Rating 2.0. All three of these actions had a direct impact on the Q&As.
This newest installment of the Q&As address those changes. Significant updates addressed by the revisions include:
- Escrow of flood insurance premiums
- The detached structure exemption
- Force placement procedures
- The acceptance of private flood insurance
In addition, the Q&As have been reorganized and are now divided into 19 topic categories. The reorganization was made to follow a better logical flow through the flood insurance process, as well as provide a completely new system of numbering of the Q&As. (What you previously may have remembered as “Question #37” or “Answer #40” no longer exists!)
The Agencies intend for the Q&As to provide meaningful guidance to help lenders meet their regulatory responsibilities. However, they did make a crucial distinction: They “are providing the interagency questions and answers as guidance only”, and they do not serve as the basis for supervisory action. This is great news for lenders! The Guidance offers practical advice, without setting a standard for violations. Superb!
Join this 2-hour on-demand recording to get the facts about this signification Guidance. You will come away better informed and prepared to manage your flood compliance program. You may need to update bank policies and procedures to align with this Guidance – some answers provide relief to creditors!
What you’ll gain from attending this webinar:
- A clear understanding of the Q&A’s new organization and numbering system
- The ability to quickly research and find the information you need in the Q&As
- A summary of what changed
- A listing of what was added
- All 144 new and updated Q&As
- An overview of Risk Rating 2.0
- Better certainty on private flood insurance policy acceptance
- A measure of relief on force placement management
- Confidence on the detached structure exemption – when it is allowed, what it applies to
- A better grasp of regulatory expectations for determining insured value
