Alert October 25, 2011

FRB, FDIC, OCC, NCUA and FCA Proposed Updated Q&As Concerning Flood Insurance

The FRB, FDIC, OCC, NCUA and Farm Credit Administration (collectively, the “Federal Agencies”), published proposed guidance that updates the Interagency Questions and Answers Regarding Flood Insurance (the “Updated Q&As”).  The Q&As were most recently published and updated in 2009.  The updated Q&As finalizes those Q&As that had been previously proposed; one concerning insurable values and another regarding force placement of flood insurance.  The Federal Agencies also requested comments in the Updated Q&As on three additional proposed revisions concerning force placement of flood insurance.  Comments to the Federal Agencies concerning the three proposed Updated Q&As and, more generally, on other issues and concerns regarding compliance with the federal flood insurance statutes and regulations, are due by December 1, 2011.