Flood rules – clarified. The agencies (FRB, OCC, FDIC, FCA and NCUA) published a proposed change for your flood rules on July 6, 2020. To be clear, this is a proposal which means it is a crystal ball of things to come, and your opportunity to comment on what the agencies believe needs to be clarified and updated. Knowing what’s in the proposal also gives you the opportunity to prepare in advance. Your comments are invited. Will what is proposed make your compliance easier, or harder?
The Questions and Answers which are some of the best guidance we have are nearly 10 years old. There will be new questions and new answers, in addition to some clarifications on existing Q&As. The proposed updated list will address several issues including:
- The escrow of flood insurance premiums;
- The detached structure exemption to the mandatory purchase of flood insurance requirement; and
- Force-placement procedures.
In the 138 page document the agencies say the proposed list also revises Q&As from the existing document to improve clarity and reorganize by topic.
We will also discuss briefly the state of enforcement actions. Penalties are not slowing up so we will talk about the most commonly cited violations in the ocean of flood compliance.