The five federal agencies (FDIC, OCC, FRB, NCUA, and Farm Credit Administration – collectively, Agencies) issued a request for public comment on new and revised Interagency Questions and Answers Regarding Flood Insurance. The existing Q&As were last updated almost a decade ago in 2011.
The Agencies’ proposal includes new Q&As covering topics, including but not limited to, the following:
- The escrow of flood insurance premiums;
- The detached structure exemption to the mandatory purchase of flood insurance requirement; and
- Force-placement procedures
In efforts to improve clarity, reduce compliance burden for lenders, and make it easier for users to locate material related to specific topics, the Agencies also propose amendments that will reorganize content by topic. While the proposed Q&As do not address the 2019 private flood insurance final rule, the Agencies plan to propose additional questions and answers to address private flood insurance requirements at a later date.
Comments to the proposal are due 60 days from the date the request is published in the Federal Register.
A copy of the Federal Register Notice can be found here.
Proctor is in the process of reviewing the proposed Q&As and their potential impact on clients’ business rules. In the mean-time, if you have any questions, please contact your client relationship manager.