1 BCAC and Connecticut Bankers Association April 1, 2015 - Flood Insurance Updates - Presented by: Samuel W. Shaw, Review Examiner Robert Ellis, Senior.

Slides:



Advertisements
Similar presentations
This is an audio-enhanced PowerPoint presentation. To hear the audio, please open this presentation in Slide Show view. Changes to the National Flood.
Advertisements

Flood Insurance - Employee Training n American Bank and Trust n 2003.
“Not your parents flood program “.  – information for the National Flood Program.  – digital flood.
FDIC Regulatory Update Bank Compliance Association of Connecticut October 2014 Hot Topics, Exam Findings and Best Practices Sherry Antonellis Field Supervisor.
Levee Decertification & CRS: How a Catch-22 Can Catch You! ASFPM 2011 National Conference Louisville, KY Wednesday, May 17, 2011 ASFPM 2011 National Conference.
KaufCAN.com 5 Days and Counting: Marketplace Opening and Other ACA Issues 2013 VAHU Conference September 26, 2013 John M. Peterson Kaufman & Canoles, P.C.
FHA Training Hope For Homeowners December Housing and Economic Recovery Act of 2008 Hope for Homeowners Overview  A temporary program to assist.
Evidence of NFIP Flood Insurance and Documenting Grandfathering
Robert Billington October 14,  Passed by Congress in March 2010  Thousands of pages  Hundreds of provisions to be implemented over several years.
Real Estate Law An Introduction to the Closing Real Estate Law An Introduction to the Closing.
© OnCourse Learning. All Rights Reserved. Closing the Real Estate Transaction Learning Objectives  List the preliminaries to closing  List the items.
Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines.
What Brokers Need to Know Broker ATRQM Safe Harbor Rebuttal Presumption 1.
Coalition for Sustainable Flood Insurance April 16, 2014 Coastal Protection and Restoration Authority 1.
Changes to the National Flood Insurance Program (NFIP) Ross Richardson Chief, Floodplain Management and Insurance FEMA Region 6 March 27, 2013.
1 ASFMRA Annual Meeting October 28, 2009 Appraisers, Lenders, and Flood Insurance.
Maine Association of Mortgage Professionals
BCAC & CONNECTICUT BANKERS ASSOCIATIONS FLOOD INSURANCE April 1, 2015 T om Young, CPCU, ARM
Confidential Information Consumer Compliance Hot Topics Brent Hassell, Supervisory Examiner Federal Reserve Bank of Richmond Banking Supervision and Regulation.
© 2015 Ticor Title Know before you close. 1 © 2015 Ticor Title Your CFPB readiness partner – every step of the way Know before you close. An Introduction.
Changes to the National Flood Insurance Program – What to Expect Impact of changes to the NFIP under Homeowner Flood Insurance Affordability Act of 2014.
1 © 2015 Fidelity National Title Group. 2 What is the CFPB?  CFPB Stands for the CONSUMER FINANCIAL PROTECTION BUREAU  It is an Independent Bureau within.
C O A L I T I O N Corner An Overview of RESPA Coalition Corner: Business training tools for HR staff, real estate licensees and other service professionals.
1 HOEPA Does Math High Cost Mortgage Rules Regulation Z - Section 32 Calculations.
1 Flood Insurance. 2 Flood - History History of the Law –National Flood Insurance Act of 1968 Federally subsidized insurance became available Voluntary.
Flood Training by Brad Bullock CRCM, First National Bank of Midland This tool can be found in the Banker Tools section of BankersOnline.com.
CH 16 Residential and Commercial Property Financing.
Session 311 Insurance “A promise of compensation for specific potential future losses in exchange for a periodic payment” Source: InvestorWords.com, 2003.
This is an audio-enhanced PowerPoint presentation. To hear the audio, please open this presentation in “Slide Show” view. More Changes Coming to the National.
SB19 Study Committee. Montana State Fund is committed to the health and economic prosperity of Montana through superior service, leadership and caring.
Prepared by National Flood Services Flood Insurance It’s more than just a lender requirement – don’t get left behind… 1.
© 2012 Medical Mutual of Ohio Fees and Taxes in Healthcare Reform Patricia Decensi Vice President, Assistant General Counsel Medical Mutual of Ohio.
Monday, May 2, 2011 W-10 Clarification of Rules and Regulations Presenters: Steve Van Dyke, Tyrone Gregory & Carleathea Greenhill Facilitator: Corise Morrison.
This is an audio-enhanced PowerPoint presentation. To hear the audio, please open this presentation in “Slide Show” view. More Changes Coming to the National.
Changes to the National Flood Insurance Program (NFIP) Understanding the Biggert-Waters Flood Insurance Reform Act of 2012 (BW12)
Presented by: Lacy Smith Wallace KAAR Affiliate Member Regions Bank.
Increased Cost of Compliance The Basics (Last updated July 25, 2006)
W-30 BW 12 and Program Changes - Overview Presenters: Joe Cecil and John Hintermister.
Health Care Reform and its Impact on Michigan Janet Olszewski, Director Michigan Department of Community Health Senate Health Policy Committee May 5, 2010.
CHAPTER 3 Objectives  Be able to discuss reasons for home ownership.  List types of housing available  Identify tax benefits of home ownership  Identify.
North Carolina Emergency Management Floodplain Management Section NC Department of Revenue 2013 Advanced Real Property Seminar Biggert-Waters National.
Commonwealth of Massachusetts Executive Office of Health and Human Services Implementing the Affordable Care Act in Massachusetts 2012 Legislative Changes.
Flood Map Modernization Flood Map Modernization Mapping the Risk Editorial Board Meeting October 2005 HILLSBOROUGH COUNTY FLOOD MAP MODERNIZATION V
New Identity Theft Rules Rodney J. Petersen, J.D. Government Relations Officer Security Task Force Coordinator EDUCAUSE.
Florida Catastrophic Storm Risk Management Center.
Interagency Q&As Introductions The Basics The Highlights The Details The Future Questions 1 NFC 2010 Workshop | April 2010 | San Diego, CA Agenda.
Chapter 16: Structure of the U.S. Housing Finance System REI 330.
© 2013 Sapers & Wallack, Inc. All rights reserved. sapers-wallack.com Tel: ACA: "Cliffs Notes" for the Busy Employer How do you meet the compliance.
Office of Affordable Housing ENVIRONMENTAL ASSESSMENT REVIEW PROCEDURES FOR THE HOME PROGRAM BY: GEORGIA DEPARTMENT OF COMMUNITY AFFAIRS OFFICE OF AFFORDABLE.
Multiple Structures: Regulations, FZD Processes & Challenges
Changes to the National Flood Insurance Program – What to Expect Impact of changes to the NFIP under the Biggert- Waters Flood Insurance and Reform Act.
The National Flood Insurance Program Edie Lohmann, FEMA Region IX NFIP Insurance Specialist.
National Flood Insurance Program Bureau and Statistical Agent Flood Insurance Two-Year Preferred Risk Policy Eligibility Extension Kristin Minich, Regional.
The Plain Truth about Flood Insurance and Floodplain Management March 24, 2016 National Hurricane Conference Orlando, Florida Jeanne M. Salvatore, Senior.
John Sebree Senior Vice President of Public Policy Flood Insurance Update Florida Senate Banking & Insurance Committee October 8, 2013.
National Flood Insurance Program (NFIP) April 1, 2016 Flood Insurance Changes.
An Introduction to the CFPB
Mortgage Industry Changes That May Impact Closing
The Final RESPA Rule.
Flood Insurance- When is it required, and How much does it cost?
Louisiana Bankers Association
Flood Damage Prevention Code Update
The National Flood Insurance Program and the State of the Market
Glynn County, GA Flood Remapping January 2018
CSFI Flood Insurance Update February 1, 2018.
Biggert-Waters Flood Insurance Reform Act of 2012 (BW12)
Reform Act 2012 A brief overview of the new Flood Insurance Reform Act 2012 Disclaimer: FEMA has not provided any guidance for the field at this time.
Rising Sea Level Predictions
Flood KNOWLEDGE. CLARITY. RELIABILITY.
Louisiana Flood Risk Coalition
Presentation transcript:

1 BCAC and Connecticut Bankers Association April 1, Flood Insurance Updates - Presented by: Samuel W. Shaw, Review Examiner Robert Ellis, Senior Compliance Examiner

2 Objectives Provide background, information and updates on: Biggert-Waters Flood Insurance Reform Act of 2012 (BW-12) Homeowner Flood Insurance Affordability Act of 2014 (HFIA-14) Common compliance pitfalls or challenges Compliance Management System (CMS) as applied to Flood Insurance compliance Questions and answers Resources 2

3 Biggert-Waters Flood Reform Act of Signed into law on July 6, 2012 Extends the NFIP to September 30, 2017 Provides financial reforms to NFIP Phases out subsidies (significant premium rate increases for many consumers) Mandates flood map update Creates reserve fund Makes changes to mandatory purchase requirements

4 Biggert-Waters Flood Reform Act of 2012 (Continued) 4 Two provisions of BW-12 became effective July 6, 2012: Civil Money Penalties (CMPs) Increased from $385 to $2,000 per violation Annual penalty cap removed (potential for unlimited, mandatory CMPs for pattern and practice violations) Force placement provisions

5 Biggert-Waters Flood Reform Act of 2012 (Continued) 5 Pattern or Practice violations of the following sections of the Flood Regulation are subject to the assessment of mandatory CMPs: § Requirement to purchase flood insurance where available § Escrow requirement § Forced placement of flood insurance § Notice of special flood hazards and availability of federal disaster relief assistance

6 Biggert-Waters Flood Reform Act of 2012 (Continued) 6 Force placement provisions Termination & Refund – within 30 days of receipt of confirmation of borrower’s existing policy Require a lender or servicer to accept as confirmation of a borrower’s existing flood insurance policy a declarations page that includes: Policy number Identity and contact info for insurer or agent FIL (March 29, 2013)

7 Biggert-Waters Flood Reform Act of 2012 (Continued) 7 BW-12 provisions requiring implementing regulations to become effective: Private Flood Insurance Escrow of Flood Insurance payments Amended by HFIA-14

8 Biggert-Waters Flood Reform Act of 2012 (Continued) 8 Other BW-12 provisions Increased maximum limit available for non-condo residential buildings designed for use for five or more families – “Other Residential Buildings” Maximum building coverage increased from $250,000 to $500,000 per building Joint Notice of Proposed Rulemaking, Loans in Areas Having Special Flood Hazards, October 30, 2013 (78 FR 65108)

9 Homeowner Flood Insurance Affordability Act of Summary of Key Features Limits annual flood insurance premium rate increases, imposes an annual surcharge, and refunds excess premiums paid under BW-12 Restores “grandfathered” status to certain properties Permits assumption of an NFIP policy upon sale of a home Introduces optional high-deductible policies Requires escrow of FI premiums on a “tripwire” approach Excludes detached structures on residential property from FI requirements

10 Homeowner Flood Insurance Affordability Act of 2014 (Continued) 10 Flood Insurance Premium Rate Increases Limits annual rate increases for primary residential properties Annual rate increases for secondary homes and non-residential properties unchanged Refunds to policyholders in the NFIP of excess premiums paid under BW-12

11 Homeowner Flood Insurance Affordability Act of 2014 (Continued) 11 Grandfathered Properties Restores grandfathered status to certain properties Grandfathered status attaches to the property Grandfathered rates subject to annual increases

12 Homeowner Flood Insurance Affordability Act of 2014 (Continued) 12 Sales of Property Purchaser of a home covered by an NFIP policy can assume the existing policy Remainder of the term will be at existing subsidized rate Rates also subject to annual increases

13 Homeowner Flood Insurance Affordability Act of 2014 (Continued) 13 Property Newly Mapped in Special Flood Hazard Area Policyholders pay preferred risk premium rate for first year Upon renewal, rates subject to annual increases

14 Homeowner Flood Insurance Affordability Act of 2014 (Continued) 14 High Deductible Policies FEMA to offer optional high deductible policies Limited to residential properties Maximum deductible of $10,000 Requires disclosure to policy applicant

15 Homeowner Flood Insurance Affordability Act of 2014 (Continued) 15 Escrow Requirements Would be required to escrow flood insurance premiums and fees for any loan secured by residential improved real estate or a mobile home that is: made, increased, extended, renewed, or refinanced on or after January 1, 2016, unless an exception applies. This requirement is effective when the Agencies issue implementing regulations.

16 Homeowner Flood Insurance Affordability Act of 2014 (Continued) 16 Escrow Requirements Would not be required to escrow premiums and fees if: Your institution has total assets of less than $1 billion; and On or before July 6, 2012, your institution: Was not required under Federal or State law to escrow taxes or insurance for the term of a loan; and Did not have a policy to require escrow of taxes and insurance.

17 Homeowner Flood Insurance Affordability Act of 2014 (Continued) 17 Escrow Requirements Expanded exemptions to include: Junior liens Condo loans Business loans HELOCs Nonperforming loans Loans with maturities < 1 year

18 Homeowner Flood Insurance Affordability Act of 2014 (Continued) 18 Exclusion of Detached Structures Effective immediately (March 21, 2014) Amends RESPA to require a disclosure

19 Homeowner Flood Insurance Affordability Act of 2014 (Continued) 19 FEMA Flood Insurance Advocate Assists current and prospective policyholders Answers questions about flood mapping and insurance rates Joint Notice of Proposed Rulemaking, Loans in Areas Having Special Flood Hazards, October 30, 2014 (79 FR 64518)

20 Common Pitfalls and Challenges Force placement of flood insurance Map changes Flood zone discrepancies Miscellaneous 20

21 Common Pitfalls and Challenges (Continued) Force Placement of Flood Insurance Notify borrower of requirement to obtain coverage Force place coverage if borrower does not obtain policy within 45 days of notification Renewing/Refinancing a loan with force placed coverage 21

22 Common Pitfalls and Challenges (Continued) Map Changes Life of loan monitoring Notifying the borrower of map changes Preferred Risk Policies 22

23 Common Pitfalls and Challenges (Continued) 23 Flood Zone Discrepancies Policy vs. Standard Flood Hazard Determination Form Use of more hazardous flood zone Effect of grandfathering

24 Common Pitfalls and Challenges (Continued) 24 Miscellaneous Notice to borrower (Q&A # 79) Proof of coverage Construction loans (Q&As 21 and 22)

25 Flood Insurance – Compliance Management System Board and Management Oversight Compliance Program Policies and Procedures Monitoring 25

26 Flood Insurance – Compliance Management System (Continued) Compliance Program (Continued) Training Audit Function 26

27 Questions? Thank you! 27

28 Resources 28 Statutes and Regulations Part 339 – Loans in Areas Having Special Flood Hazards (FDIC’s implementing regulation) Joint Notice of Proposed Rulemaking on Loans in Areas Having Special Flood Hazards October 21, Biggert-Waters Flood Insurance Reform Act of Consolidated Appropriations Act – Homeowners Flood Insurance Affordability Act of

29 Resources (Continued)

30 Resources (Continued) FEMA Guidance on NFIP FEMA Guidance on Flood Insurance Reform Standard Flood Hazard Determination Form library/assets/documents/225?id=1394 FEMA – April 16, 2008 – W Procedures Relating to Flood Zone Discrepancies NFIP Flood Insurance Manual, effective June 1,