Consumer Finance Insights
February 25, 2015

Local Bank Fined for Failing to Notify Borrowers of Flood Insurance Requirement

On February 25, 2015, a state bank entered into a consent order with the FDIC, relating to allegations that the bank had violated section 102(f)(4) of the Flood Disaster Protection Act of 1973, 42 U.S.C. § 4012a(f)(4), and the FDIC Rules and Regulations promulgated thereunder, by failing to notify borrowers whose property was located in a Special Flood Hazard Area that they needed to obtain separate flood insurance or supplemental flood insurance. The FDIC determined that the bank had violated the FDIC Rules and Regulations by failing to obtain adequate flood insurance at the time of origination for one loan; failing to follow force placement flood insurance procedures for seven loans, and failing to provide borrowers a Notice of Special Flood Hazard and Availability of Federal Disaster Relief Assistance for seven loans. 12 C.F.R. §§ 339.3(a), 339.7, 339.9(a). As part of the consent order, the bank agreed to pay a civil money penalty. The FDIC ordered the bank to pay a $10,600 penalty.