Feds Seek Proposed Revisions to Interagency Q&As Regarding Flood Insurance

Jun 26, 2020

Five federal regulatory agencies—the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board), Federal Deposit Insurance Corporation (FDIC), Farm Credit Administration (FCA), and the National Credit Union Administration (NCUA)—requested public comment on new and revised Interagency Questions and Answers Regarding Flood Insurance. The Interagency Questions and Answers, which provide information addressing technical flood insurance-related compliance issues, were last updated in 2011.

The five federal agencies are proposing new questions and answers for inclusion in the Interagency Questions and Answers in light of changes to flood insurance requirements under the agencies’ joint rule regarding loans in special flood hazard areas. This rule was promulgated in 2015 to implement provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 and the Homeowner Flood Insurance Affordability Act of 2014.

The proposal incorporates new questions and answers in several areas, including:

►The escrow of flood insurance premiums;
►The detached structure exemption to the mandatory purchase of flood insurance requirement; and
►Force-placement procedures.

The proposal also revises existing questions and answers to improve clarity and reorganizes questions and answers by topic to make it easier for users to find and review information related to technical flood insurance topics. The proposal is intended to help reduce the compliance burden for lenders related to the federal flood insurance laws.

Separately, the agencies plan to propose new questions and answers at a later date on the private flood insurance requirements implemented by their February 2019 final rule. The agencies invite comment on this proposal. Comments will be accepted for 60 days after publication in the Federal Register.

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Jun 26, 2020

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