So, the Government may shut down. Again. This has happened before and will likely happen again. When this happens, one of the many “non-essential” services and programs is the National Flood Insurance Program (NFIP). So, what do we do if/when a shutdown happens? If there is a disruption to the NFIP, we should be prepared […]
In a Government Shutdown the National Flood Insurance Program Could be Affected Read More »
The death knell for junk fees has sounded. There are emerging compliance risks surrounding junk fees that are gaining steam in Washington. While not new, the intensity or vigor of the current administrations’ pursuit of crimes (in their estimation) is increasing. Below is a link to two ABA article summaries which just came out on
Time to Put Your Junk in the Trunk? Read More »
Answer: Because the overall term of the C-P loan is greater than 12 months, you are required to escrow for flood insurance. The fact that the construction phase is 12 months or less is irrelevant. This means that you must require flood insurance at consummation.
Effective October 1, 2021, FEMA updated its Special Flood Insurance Policy forms to bring them in conformance with the requirements stipulated in the final rule FEMA published in July 2020, “Conforming Changes To Reflect the Biggert-Waters Flood Insurance Reform Act of 2012 (BW-12) and the Homeowners Flood Insurance Affordability Act of 2014 (HFIAA), and Additional
FEMA Changes Declaration Pages Read More »
Over the past several months, the banking industry has experienced tremendous loan origination volume. While increased loan production is a good thing, it is important for Compliance Managers to stay cognizant of rising risks. Pressure, whether from peers or self-imposed, to push loans through leads to a breakdown in controls that are caused from procedural
When the Tide is Against You Read More »
TCA’s February 7, 2019 Special Release “Final Rules Released for Acceptance of Private Flood Insurance” said lenders can accept a private flood insurance policy and easily identify an acceptable policy. The rule suggests private providers add the following “compliance aid” clause: ‘‘This policy meets the definition of private flood insurance contained in 42 U.S.C. 4012a(b)(7)
Accepting Private Flood Insurance Policy – Two Choices Read More »
On December 21, 2018, the President signed legislation that extended the National Flood Insurance Program’s (NFIP’s) authorization to May 31, 2019. All was well for another six months, or so everyone (including Congress) thought. On December 27th, FEMA ruled that the NFIP extension doesn’t allow for its continuation during the ongoing government shutdown. This decision
Important Update National Flood Insurance Program—What’s Going On? Read More »
On November 20, 2018, FEMA posted a press release reminding interested parties that the National Flood Insurance program (NFIP) expires at 11:59 p.m. on November 30, 2018. While FEMA is confident Washington will vote to reauthorize the NFIP, if a lapse were to occur, it would not impact policies already in effect. We will continue
Will National Flood Insurance Program Expire? Read More »
Keeping Your Compliance Program Afloat Key webinar topics include: Flood determination timing The Standard Flood Hazard Form. Required coverage calculation Key data on the declaration page Coverage for “abundance of caution” collateral Clarify detached structure requirements Required documentation prior to closing Tracking and monitoring coverage for existing loans Coverage of commercial buildings Definition of a
National Flood Insurance Act Read More »
Washington pulled through with a temporary compromise on extending government funding on Monday, thereby continuing to fund many “non‐essential” services and programs – one of which is the National Flood Insurance Program (NFIP). However, this provides us with a three week window and if additional compromises or an agreement is not made we may find
Government Shutdown—National Flood Insurance Program Affected Read More »
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