The agencies invite comments on the proposed new and revised interagency questions and answers. Comments must be submitted on or before
The agencies plan to issue separately for notice and comment new proposed questions and answers relating to the private flood insurance rule./2 In the interim, the agencies provided in a webinar dated
The proposed revisions to the interagency questions and answers would apply to all OCC-supervised banks./3
To help lenders meet their responsibilities under federal flood insurance law and to increase public understanding of flood insurance regulations, the agencies are proposing new and revised guidance addressing the most frequently asked questions and answers on flood insurance. The document
* reorganizes the existing interagency questions and answers on flood insurance to provide a more logical flow of questions through the flood insurance process for lenders and policyholders.
* includes a table that sets forth the existing categories of questions and the corresponding reorganized categories.
* reflects proposed changes to the 2009 and 2011 interagency questions and answers.
* includes new questions and answers on the escrow and force placement requirements mandated by the Biggert-Waters Act of 2012 and the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA), as well as the exemption in the HFIAA for certain detached structures from the mandatory purchase of flood insurance requirement.
* reflects flood insurance issues that have been brought to the attention of the agencies, including issues raised through the review process directed by the Economic Growth and Regulatory Paperwork Reduction Act of 1996.
* "Loans in Areas Having Special Flood Hazards;
1/ OCC Bulletin 2009-26, "Flood Disaster Protection Act:
2/ 84 Fed. Reg. 4953 (
3/ The term "banks" refers collectively to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.