Bulletin outlines flood insurance Qs and As for national banks, savings associations

Flood insurance questions and answers are outlined in a bulletin issued Tuesday by the regulator of national banks, following up on an interagency notice issued earlier in the month.

The Office of the Comptroller of the Currency (OCC) said its bulletin 2022-16 offers several points about the interagency notice, including that:

  • The 2009 and 2011 interagency questions and answers are reorganized to provide a more logical flow through the flood insurance process for lenders and policyholders.
  • Flood insurance issues are addressed that have been brought to the agencies’ attention, including those raised through the review process directed by the Economic Growth and Regulatory Paperwork Reduction Act of 1996.
  • New questions and answers are included on escrow of flood insurance premiums, the detached structure exemption, force placement procedures, and acceptance of flood insurance policies issued by private insurers.
  • Interagency Questions and Answers Regarding Flood Insurance conveyed by OCC Bulletins 2009-26 and 2011-42 are replaced.
  • The Proposed Revisions to Interagency Questions and Answers Regarding Flood Insurance conveyed by OCC Bulletin 2020-69 and the Proposed Interagency Questions and Answers Regarding Private Flood Insurance conveyed by OCC Bulletin 2021-13 are consolidated. The questions and answers published revise, as appropriate and based on comments received, the proposed questions and answers.
  • A table that sets forth the existing categories of questions and the corresponding reorganized categories are included.

OCC Bulletin 2022-16: Flood Disaster Protection Act: 2022 Interagency Questions and Answers Regarding Flood Insurance