Topics In This Issue
• Federal Issues
• Firm News
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Excerpt from Insurance:
Federal Agencies Release Guidance and Proposed Revisions to Interagency Questions and Answers Regarding Flood Insurance. On October 14, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Farm Credit Administration, and National Credit Union Administration (collectively, the Agencies) published guidance and proposed revisions to the Interagency Questions and Answers Regarding Flood Insurance, most recently published on July 21, 2009. The Agencies finalized two new questions and answers, one relating to insurable value and one relating to force placement, and withdrew one question and answer regarding insurable value. The guidance also significantly revises and requests comments on three questions and answers regarding force placement of flood insurance. Under the new guidance, the Agencies reaffirm that the insurable value for certain residential or condominium properties should be written to the replacement cost value (RCV) but, in calculating the required amount of insurance, the lender and borrower may choose from a variety of approaches or methods to establish a reasonable valuation. In addition, the Agencies provided that any delay in purchasing a flood insurance policy must be brief when the borrower has failed to purchase an appropriate policy within the 45-day notice period, and the lender must provide a reasonable explanation for any such delay. The final questions and answers are effective as of the date of publication in the Federal Register, and comments on the proposed questions and answers must be submitted within 45 days after such publication...
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