Revised FDPA Interagency Exam Procedures

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:

Federal Reserve

OCC

Please contact your client relationship manager if you have any questions.

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