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Financial Services Law Insights and Observations

Agencies propose updates to Interagency Questions and Answers Regarding Flood Insurance

Agency Rule-Making & Guidance FDIC Flood Insurance Mortgages Force-placed Insurance

Agency Rule-Making & Guidance

On June 26, the FDIC, OCC, Federal Reserve Board, NCUA, and the Farm Credit Administration issued a request for public comments on proposed new questions and answers to be included in the Interagency Questions and Answers Regarding Flood Insurance, following changes made to flood insurance regulations under the agencies’ joint rule regarding loans in special flood hazard areas. The proposal updates interagency questions and answers last updated in 2011, and is intended to reduce compliance burdens for lenders related to flood insurance laws. Among the new questions and answers are those related to (i) the “escrow of flood insurance premiums”; (ii) the “detached structure exemption to the mandatory purchase of flood insurance requirement”; and (iii) force-placement of flood insurance procedures. The proposal also revises and reorganizes several existing questions and answers to improve clarity and user functionality. Comments will be accepted for 60 days following publication in the Federal Register.

Additionally, FDIC FIL 67-2020 states that the agencies are currently drafting new Interagency Questions and Answers Regarding Flood Insurance related to the 2019 private flood insurance rule (covered by InfoBytes here), which will be proposed at a later date.

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