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FEDERAL AGENCIES ISSUE UPDATED INTERAGENCY FLOOD INSURANCE Q&AS

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 National Credit Union Administration (“NCUA”) (collectively, the “Agencies”) recently issued revised and expanded interagency questions and answers (“Q&As”) regarding federal flood insurance laws.

The guidance, titled Loans in Areas Having Special Flood Hazards; Interagency Questions and Answers Regarding Flood Insurance, covers major amendments to federal flood insurance laws with regard to the escrow of flood insurance premiums, the detached structure exemption, force placement procedures and the acceptance of flood insurance policies issued by private insurers.

The new released Q&As consolidation and supersede the sets of Q&As released by the Agencies in July 2020 and March 2021 which addressed changes to flood insurance requirements under the Biggert-Waters Flood Insurance Reform Act and the Homeowner Flood Insurance Affordability Act. In addition to expanded guidance, the new Q&As are reorganized for easier reference.

It should be noted that the Agencies state the new Q&As are provided only as “guidance” under the regulations and applies to both the National Flood Insurance Program and private flood insurance.

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Topics from this blog: Compliance

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