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Friday, August 1, 2014

Agencies Decline ABA Request for Flood Insurance Guidance

The federal financial regulators on Wednesday told ABA they would not be able to provide requested information to facilitate compliance with the 2012 Biggert-Waters flood insurance reform law and this year’s Homeowner Flood Insurance Affordability Act, which addressed affordability problems in Biggert-Waters.

ABA had written the agencies in April asking for timetables and implementation plans and agency expectations for flood insurance changes. The association also asked the agencies to work with FEMA to update and maintain Mandatory Purchase of Flood Insurance Guidelines, a publication that is widely relied on by the industry.

Acknowledging “[t]he importance of information and guidance to institutions in light of the various statutory changes,” the interagency letter nevertheless disavowed responsibility for updating the guidance because “much of the information contained in the [Guidelines] pertained to flood insurance matters outside of the Agencies’ authority.”

In the same letter, the agencies announced that “provisions pertaining to detached structures [HFIAA §13] became effective upon enactment.” HFIAA §13 permits a bank to exercise its discretion not to require a flood policy covering detached, non-residential structures. ABA has long sought such clarity on when this pro-consumer provision became effective and welcomed the statement.

Read ABA's letter.

Read the agencies’ response.

For more information, please contact ABIA's Kevin McKechnie.