Alert March 25, 2008

Federal Banking Agencies Release Proposed Revisions to Interagency Flood Insurance Questions and Answers

The federal banking agencies released for comment new and revised interagency questions and answers regarding flood insurance. The proposed changes include substantive modifications to questions and answers pertaining to construction loans and condominiums. The agencies also propose new questions and answers in a number of areas, including second lien mortgages, the imposition of civil money penalties, and loan syndications/participations. Finally, the agencies propose to revise and reorganize certain existing questions and answers to clarify areas of potential misunderstanding and to provide clearer guidance. Comments are due May 20, 2008. Click here for the proposal.