The flood insurance regulations have been around since 1996 (the Act since the 60s!), yet examiners continue to cite numerous violations and fines. Compliance seems simple but is much more difficult in practice. Flood insurance compliance is always one of the regulators' principal areas of concern. We've also had changes in the law, dating back to the Biggert-Waters Flood Insurance Reform Act of 2012, that has influenced compliance efforts. The agencies recently issued proposed Interagency Q&As to deal with the private flood insurance provisions. At some point in the future, there will be significant changes coming to the program due to severe financial issues. These changes won’t just change the economics of the program; there will be compliance changes, too. We’re not positive what those will be yet, but there are tea leaves to read.
We'll concentrate on some of the more vexing current issues in flood compliance, such as monitoring, contents coverage, and the ever-present condo problem, by talking through sample scenarios and explaining best practices in keeping your portfolio covered.
- Private flood insurance regulations and Interagency Q&As – what do they mean and how does our institution comply?
- What might happen to the NFIP when Congress gets around to amending the program? What will the compliance implications be?
- What exactly do the flood insurance rules cover?
- What is a covered structure or an insurable mobile home?
- Determinations: when you must do them, reliance upon previous determinations, disputes over their results, and the role of life-of-loan coverage
- Flood zone discrepancies - how to deal with them
- Insurable value - what is it and how is it calculated?
- Coverage Amounts: "Normal" situations, condo coverage, multi-structure, and construction situations
- "Knowledge is King" - when you have to know
- Documentation and retention: the Standard Flood Hazard Determination Form, notice to customers, and proof of insurance
- What do you have to monitor?
- The types of policies and their limitations, including NFIP (National Flood Insurance Program) and private policies
- Force-placing insurance - why and how
- Insurance premiums and Congressional action
- Increasing regulatory expectations
Who Should Attend?
This interactive session will give an in-depth understanding of these rules and is imperative for anyone performing duties in real estate lending areas of the financial institution. This includes loan officers, supervisors, auditors, closing agents, compliance officers, trainers, and others working in these types of positions.
Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Managing Director for Treliant Risk Advisors in Washington, DC. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.
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