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Financial Services Law Insights and Observations

OCC announces FEMA's flood insurance payment deadline extension

Federal Issues Agency Rule-Making & Guidance OCC FEMA National Flood Insurance Program Flood Insurance Force-placed Insurance Covid-19

Federal Issues

On April 15, the OCC released a statement addressing the Federal Emergency Management Agency’s (FEMA) extension to the grace period for renewing flood insurance policies from 30 days to 120 days due to the Covid-19 pandemic. FEMA’s guidance in Bulletin W-20002 relates to National Flood Insurance Program policies with expiration dates from February 13, 2020 to June 15, 2020, and states that coverage will not lapse if the policy premium is paid prior to the end of the extended grace period. FEMA’s bulletin indicates that the payment grace period was extended “to allow additional time for policyholders who may be struggling financially during this unprecedented time to pay insurance premiums by ensuring that their policies are not canceled for nonpayment of premium due to circumstances beyond their control.” Likewise, the OCC statement “recognizes the serious impact the COVID-19 emergency may have on consumers” and conveys that it will not take enforcement or supervisory action against banks for “reasonable delays in complying with” the OCC’s force placement of flood insurance regulations. The OCC reminds banks that if flood insurance is force placed during the extended grace period, the banks must refund the cost of the overlapping coverage to the borrower.