As homeowners file insurance claims for property damage following Hurricane Ida and with Hurricane Larry threatening the northeast coast, mortgage servicers are facing an influx of insurance proceeds or loss draft funds. To avoid borrower litigation and to protect against potential liability to borrowers and investors, mortgage servicers must ensure that all loss draft activities
FEMA Releases Flood Insurance Rating Methodology Under Risk Rating 2.0
On April 1, 2021, FEMA released its highly anticipated flood insurance rating methodology, Risk Rating 2.0-Equity in Action.
FEMA first announced “Risk Rating 2.0-Equity in Action” in March 2019 as an effort to improve flood maps and offer rates that are fair, easy to understand, and more aligned with a property’s unique flood risks. The
New York DFS Turns Up the Heat with Climate Change Bulletin
The New York Department of Financial Services (DFS) has issued a bulletin on climate change and financial risks to the financial institutions and insurance companies it supervises regarding the impact of climate change on those institutions. DFS asserts that “[f]inancial risks from climate change are unprecedented” and notes a warning from the Bank for International
In the Strangest Year Ever, We’re Very Thankful and Wish You a Happy Thanksgiving
As everyone steps away from their (home) office to celebrate Thanksgiving, we wanted to count our blessings as we review this truly remarkable and unusual year. In addition to frontline healthcare workers, good WI-FI, food delivery services, and finally finding a mask that is comfortable, we are also thankful for the following:
1. The CARES
FHA Posts Proposed Rule Permitting Acceptance of Private Flood Insurance
On November 10, 2020, the U.S. Department of Housing and Urban Development (HUD) released a proposed amendment to Federal Housing Administration (FHA) regulations that would allow lenders to accept private flood insurance policies on FHA-insured properties located in Special Flood Hazard Areas. HUD will accept comments for 60 days following the date the proposed rule,
Federal Agencies to Update Q&As Regarding Flood Insurance
It has been nine years since the Interagency Questions and Answers Regarding Flood Insurance (Flood Insurance Q&As) have seen any revisions. But that’s all about to change. Under the National Flood Insurance Reform Act of 1994 (Reform Act), the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System,
Flood Insurance: Busy Hurricane Season Ahead and COVID-19 Extension
June 1 marked the start of hurricane season, and according to the National Oceanic and Atmospheric Administration (NOAA), the Atlantic hurricane season will be a busy one. NOAA predicts a 60% chance of an above-normal season, a 30% chance of a near-normal season and only a 10% chance of a below-normal season. Since June 1,
Regulators Release Updated Examination Procedures for Acceptance of Private Flood Insurance
The final rule promulgated by the Board of Governors of the Federal Reserve (Federal Reserve), the Farm Credit Administration, the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration, and the Office of the Comptroller of the Currency (OCC) went into effect on July 1, 2019, to implement the portion of the Biggert-Waters Flood
Private Flood Insurance Mandatory Acceptance Begins July 1, 2019
In February 2019, the Board of Governors of the Federal Reserve System, the Farm Credit Administration, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (the interagency regulators) issued a final rule implementing the portion of the Biggert-Waters Flood Insurance Reform Act mandating acceptance of
Flood Insurance Regulation Update: Joint Final Rule Issued
The often challenging area of flood insurance requirements, including lender-placed insurance, has become a bit clearer for lenders and loan servicers. Five of the federal banking regulatory agencies (Federal Deposit Insurance Corporation, Federal Reserve Board, Office of the Comptroller of the Currency, Farm Credit Administration, and National Credit Union Administration) recently issued a joint final