Client Login

Industry News

Regulatory Agencies Release Revisions to Interagency Questions and Answers and Proposed New Questions Regarding Flood Insurance

On July 21, 2009 the federal bank, thrift, credit union, and Farm Credit System regulatory agencies released the long awaited, revised interagency questions and answers regarding flood insurance and requested public comment on several new questions.

As with other Q&A's. the Interagency Questions and Answers Regarding Flood Insurance (2009) supersedes the 1997 interagency questions and answers document and supplements other guidance or interpretations issued by the agencies and the Federal Emergency Management Agency (FEMA). The Interagency Questions and Answers Regarding Flood Insurance (2009) consists of 77 questions and answers, which were revised based in part on comments received during the public comment period.

Given the many diverse opinions shared, the agencies also proposed for public comment five new questions and answers on determining insurable value in calculating the maximum limit of coverage available for the particular type of property and the timing of force placement of required flood insurance by lenders. After receiving and considering public comment on the five new proposed questions and answers, the agencies intend to incorporate them into the Interagency Questions and Answers Regarding Flood Insurance (2009).

The Federal Deposit Insurance Corporation, Federal Reserve Board, National Credit Union Administration, Office of the Comptroller of the Currency, Office of Thrift Supervision, and Farm Credit Administration invited comment on the five proposed questions and answers and, more generally, on other issues and concerns regarding compliance with the federal flood insurance statutes and regulations. Comments specific to the proposed questions and answers regarding determination of insurable value and force placement of required flood insurance carry a September 21, 2009 submission deadline.

This is a link to the above referenced Federal Register notice and instructions on how to submit comments. You are encouraged to share your thoughts.