Flood Disaster Protection Act: 2022 Interagency Questions and Answers Regarding Flood Insurance

Summary

On May 11, 2022, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Farm Credit Administration, and the National Credit Union Administration (collectively, agencies) issued “Loans in Areas Having Special Flood Hazards; Interagency Questions and Answers Regarding Flood Insurance.” The interagency questions and answers issued replace the ones originally published in 2009 and 2011 and consolidate questions and answers proposed by the agencies in July 2020 and in March 2021.

Rescissions

This bulletin rescinds

• OCC Bulletin 2009-26, “Flood Disaster Protection Act: Revised Interagency Questions and Answers Regarding Flood Insurance.”
• OCC Bulletin 2011-42, “Flood Disaster Protection Act: Interagency Questions and Answers Regarding Flood Insurance.”
• OCC Bulletin 2020-69, “Flood Disaster Protection Act: Proposed Revisions to Interagency Questions and Answers Regarding Flood Insurance.”
• OCC Bulletin 2020-78, “Flood Disaster Protection Act: Agencies Extend Comment Period on Proposed Revisions to Interagency Questions and Answers Regarding Flood Insurance.”
• OCC Bulletin 2021-13, “Flood Disaster Protection Act: Proposed Interagency Questions and Answers Regarding Private Flood Insurance.”

Highlights

The interagency questions and answers published today

• reorganize the 2009 and 2011 interagency questions and answers to provide a more logical flow through the flood insurance process for lenders and policyholders.
• address the flood insurance issues 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.
• include new questions and answers on escrow of flood insurance premiums, the detached structure exemption, force placement procedures, and acceptance of flood insurance policies issued by private insurers.
• replace the Interagency Questions and Answers Regarding Flood Insurance conveyed by OCC Bulletins 2009-26 and 2011-42.
• consolidate 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. The questions and answers published today revise, as appropriate and based on comments received, the proposed questions and answers.
• include a table that sets forth the existing categories of questions and the corresponding reorganized categories.

Further Information

Please contact Paul R. Reymann, Director for Consumer Compliance Policy, at (202) 649-5470.

Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

Related Link

• “Loans in Areas Having Special Flood Hazards; Interagency Questions and Answers Regarding Flood Insurance” (PDF)