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Flood Insurance: Compliance and Enforcement Challenges

Compliance with the flood insurance regulations should be easy – determine where the structure is (assuming it’s insurable) and if it’s in a flood zone, require insurance. Simple, right? Why then are there so many violations and penalties?

Upcoming
Wednesday, January 29th, 2025
10:00 am - 12:00 pm
Presented by Carl Pry
2.5 CRCM Credits
$299.00 or 1 Token

Includes: Live Access, 30 Days OnDemand Playback, Presenter Materials and Handouts

  • Auditing
  • Commercial/Business Lending
  • Compliance
  • Lending
  • Lending Compliance
  • Reporting
  • Risk Management/Legal
  • Bank Legal Counsel
  • Branch Manager
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  • Compliance Officer
  • Consumer Lender/Retail Banker
  • Credit Analyst
  • Internal Auditor
  • Loan Closer
  • Loan Operations Manager/Specialist
  • Mortgage Lender
  • Private Banker
  • Risk Manager
  • Senior Management
  • Small Business Lender
  • Training Manager
  • Trainer
  • Workout Specialist/Collector

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The reason there are so many violations is, of course, that this seemingly simple issue has many complexities. The rules have been around since 1996, yet examiners continue to cite numerous violations and fines.

Flood insurance is always one of the regulators’ principal areas of concern. We’ve also had many changes in the law over the years due to several statutory changes and other regulatory clarifications. And we now have updated and detailed interagency questions and answers that clarify many points regarding the changes, which is certainly welcome.

Nevertheless, there are many significant issues out there. In this webinar, we'll concentrate on them, including determinations, mapping (including Risk Rating 2.0), monitoring, contents coverage, private policies, amount of coverage, force-placement, and escrow requirements, among many others. We’ll devote special attention to those issues that typically cause lenders problems, as well as those that are the focus of many a regulatory violation and fine.

Come prepared with your questions, as this is the time to understand all the intricacies of the rules and ensure your processes are up to date and correct.

What You'll Learn

  • What exactly do the flood insurance rules cover? “Covered loan” vs. “Designated loan”
  • What is an insurable structure or an insurable mobile home?
  • Determinations: When you must do them, reliance upon previous determinations, disputes over their results, and the role of life-of-loan coverage
  • Flood zone discrepancies: How to deal with them (hint: you don’t have to)
  • Insurable value: What is it and how is it calculated? Is it 100% RCV? (hint: not necessarily)
  • Differences in the types of structures and impacts on coverage amounts
  • Coverage Amounts: “Normal” situations, condo coverage (including the RCBAP), multi-structure, and construction situations
  • What you have to do vs. best practices (i.e. what you can do)
  • “Knowledge is King” – When you have to know
  • Documentation and retention: The Standard Flood Hazard Determination Form, notice to customers, and proof of insurance – what you must maintain
  • What do you have to monitor?
  • The types of policies and their limitations, including NFIP and private policies
  • Private flood policies: Criteria for acceptance
  • Detached structure guidance and insuring multiple structures
  • Force-placing insurance: When, why, and how
  • Insurance premiums and potential future Congressional action
  • Continuing regulatory expectations

Who Should Attend

This interactive session will give an in-depth understanding of these rules and is imperative for anyone performing duties in real estate lending areas of the financial institution, including loan officers, supervisors, auditors, closing agents, compliance officers, trainers, and others working in these types of positions.

Carl Pry

Instructor Bio

Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Senior Advisor for Asurity Advisors in Washington, DC. Through his more than 30-year working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves as the Chair of the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.

Continuing Education Credit Information

Flood Insurance: Compliance and Enforcement Challenges has been approved for 2.5 CRCM credits. This statement is not an endorsement of this program or its sponsor. Credits are redeemable for both Live and OnDemand viewing. For questions on certificates, please email support@oncourselearning.com. Certification holders must report these credits at https://aba.csod.com.

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