The Federal Reserve and the Office of the Comptroller of the Currency announced updates to Interagency Examination Procedures for the Flood Disaster Protection Act (FDPA) through Consumer Affairs Letter CA-19-10 and OCC Bulletin 2019-42. The updated procedures include new sections pertaining to the following topics associated with the February 20, 2019 (84 FR 4953) final interagency rule addressing private flood insurance:
- Mandatory acceptance of a private insurance policy to satisfy the flood insurance purchase requirement if the policy meets the statutory and regulatory definition of “private flood insurance;”
- Discretionary acceptance of a flood insurance policy issued by a private insurer, even if the policy does not meet the statutory and regulatory definition of “private flood insurance;” and
- Discretionary acceptance of a plan issued by a mutual aid society in satisfaction of the flood insurance purchase requirement, if certain criteria are met.
The Agencies indicate that consumer complaints submitted to the lender can be utilized as a source of information regarding private flood policies that were not accepted.
A copy of the revised Interagency Exam Procedures can be found below:
Please contact your client relationship manager if you have any questions.