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By Scott Birrenkott

Q: Have the Agencies Finalized Their Revised Flood Q&As?

A: Yes. The OCC, FRB, FDIC, FCA, and NUCA (agencies) have reorganized, revised, and expanded the Interagency Questions and Answers Regarding Flood Insurance (Revised Flood Q&A).

Flood matters continue to be a hot topic with the examiners, and the Revised Flood Q&As are a helpful tool in working through many of the issues associated with flood compliance. The agencies previously issued flood interpretations, but those resources were scattered and found within various guidance documents such as the 2009 and 2011 Q&As. The Revised Flood Q&As supersede and replace those resources by consolidating and updating them into a single document.

The Revised Flood Q&As are organized by category and broken down into numerical designations within their categories. The agencies plan to update and manage these categories accordingly in the future. As an example of the benefit of the Revised Flood Q&As, examiners have recently been reviewing cross-collateralization and contents coverage calculations. The new category labeled “Other Security Interests” includes helpful discussion regarding such matters. For example, “Other Security Interests 7” discusses when flood insurance is required on contents, including examples of how to calculate. Question 8 then discusses a situation in which the contents might be located in another building, and question 9 covers applicability to contents taken as an “abundance of caution.” WBA has recently received questions regarding when contents coverage is required, as well as how to calculate insurable value when contents is included. These updated Q&As are helpful in understanding how the regulators view such situations.

While the flood rules themselves have not changed, the Revised Flood Q&As have been updated for ease of use and remain an excellent resource to consult when faced with a flood question. For any questions on flood matters or other compliance, also consider reaching out to WBA legal at wbalegal@wisbank.com or 608-441-1200.

Events

The 2023 WBA Residential Mortgage Lending School will be held April 11 – 14 at the Wisconsin Bankers Association Office in Madison. Classes will begin at 9:00 a.m. and conclude at 2:30 p.m.

Students will gain the knowledge and tools needed to be successful in this complex and highly competitive field. You will learn from seasoned professionals the concepts needed to reach that success and also learn from your fellow students through case study work as you and other team members collaborate on assignments. 

Curriculum Includes:

  • Finance Basics
  • Compliance for Residential Mortgage Lenders, Including:
    • Truth in Lending (Regulation Z)
    • FACT Act
    • ECOA (Regulation B)
    • HMDA (Regulation C)
    • Flood Protection Act
    • SAFE Act
    • Fair Lending
  • Application Generation
  • Product Knowledge
    • Conventional mortgage products
    • Government programs available for residential loans
    • Construction loans
  • Underwriting
  • Application Process
  • Sales Skills
  • Title Insurance
  • Closing Documentation
  • Pricing Considerations
  • Valuable Networking Opportunites

Attendees will also participate in a group case study that encompasses the full curriculum.

Who Should Attend?

Personal bankers, consumer lenders, loan processors, closers and new residential mortgage lenders.

Registration Information:

The student fee of $1,045 includes program registration, instruction and materials, most meals, and a Real Estate Master II Qualifier Plus calculator. Enrollment Limit: 40.