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Financial Services Law Insights and Observations

Fed issues two enforcement actions for flood insurance violations

Federal Issues Federal Reserve Enforcement Flood Insurance National Flood Insurance Act

Federal Issues

On August 20, the Federal Reserve Board announced enforcement actions against two separate Massachusetts-based banks for allegedly violating the National Flood Insurance Act (NFIA) and Regulation H, which implements the NFIA. The first consent order assesses a $20,000 penalty against the bank for a pattern or practice of violations of Regulation H, but does not specify the number or the precise nature of the alleged violations; the second consent order assesses a $36,000 penalty, while similarly not specifying the number or precise nature of the violations. The maximum civil money penalty under the NFIA for a pattern or practice of violations is $2,000 per violation.

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