The flood insurance regulations have been around since 1996, yet examiners continue to cite numerous violations and fines. Flood has been announced as one of the regulators' principal areas of concern. We've also had changes in the law, with the Biggert-Waters Flood Insurance Reform Act of 2012, that has influenced compliance efforts. The NFIP was temporarily extended through the end of this year but there are 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.
- 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
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