Thread Options
|
#1726806 - 08/02/12 08:09 PM
Biggert-Waters Flood Insurance Reform Act of 2012
|
Gold Star
Joined: Apr 2011
Posts: 257
West Virginia
|
Does anyone know when the provisions of this Act will be implemented??
|
Return to Top
|
|
|
|
#1729063 - 08/09/12 12:14 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ComplianceGrl15
|
Gold Star
Joined: Dec 2009
Posts: 298
New York
|
I'm getting hounded by staff wondering what the compliance dates are with these new provisions...it certainly would be nice if they were clear about things if they want us to comply.
|
Return to Top
|
|
|
|
#1729079 - 08/09/12 01:04 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ComplianceGrl15
|
Platinum Poster
Joined: Jan 2007
Posts: 645
|
One provision states: A requirement that a notice by given to all borrowers of loans secured by improved real estate, whether the real estate is or is not in a designated flood hazard area, that flood insurance is available from the NFIP or from a private company.
So the institution must let the borrower know with a new disclosure that insurance is available to them even if their property is not in a flood zone?
|
Return to Top
|
|
|
|
#1729169 - 08/09/12 03:05 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ComplianceGrl15
|
Power Poster
Joined: Aug 2002
Posts: 3,094
|
Yes under a RESPA amendment
_________________________
Opinions are my own and not of my employer.
|
Return to Top
|
|
|
|
#1729516 - 08/10/12 12:22 AM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ItsJustMe
|
10K Club
Joined: Jul 2001
Posts: 84,333
Galveston, TX
|
I'm getting hounded by staff wondering what the compliance dates are with these new provisions... Tell them as soon as the effective dates and implementing regulations are announced, they can be assured that you will let them know. In the mean time, they should ensure that they continue to follow Bank policies and procedures to the letter as they can rest assured that the $2,000 per violation penalty will be considered in effect as the day of passage of the law.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#1729887 - 08/10/12 08:33 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ComplianceGrl15
|
Gold Star
Joined: Dec 2009
Posts: 298
New York
|
I just received an email from FEMA. The new SFHDF will not be required to be used until May 30, 2015 - the renewal date of the form. Their web site will be updated in a couple of days with this information.
|
Return to Top
|
|
|
|
#1729904 - 08/10/12 09:11 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ItsJustMe
|
Gold Star
Joined: Dec 2006
Posts: 253
|
The new SFHDF will not be required to be used until May 30, 2015 - the renewal date of the form. That's the expiration date of the new form.
|
Return to Top
|
|
|
|
#1729912 - 08/10/12 09:30 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ComplianceGrl15
|
Gold Star
Joined: Apr 2011
Posts: 257
West Virginia
|
Okay, so now it seems as if we will have 3 disclosures to worry about?
One for all improved properties no matter if they are located in a SFHA or not - RESPA Ammendment
The new one stating that private insurance is available and for the consumer to check the price difference b/t private and NFIP.
And then the Notice of Special Flood Hazard Area for properties located in a SFHA for participating and non-participating communities.
Right??? Or will the old Notice of Special Flood Hazard Area disappear???
|
Return to Top
|
|
|
|
#1729968 - 08/12/12 12:00 AM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ComplianceGrl15
|
10K Club
Joined: Jul 2001
Posts: 84,333
Galveston, TX
|
I agree with KB. This is like speculating what the final version of the TIL/RESPA disclosure was going to look like a year ago. Concentrate on known issues (god knows there are enough of those) and don't worry about the unknown until we have some guidance issued.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#1749357 - 10/15/12 07:19 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ComplianceGrl15
|
10K Club
Joined: May 2004
Posts: 10,124
Way, way south.
|
Not a member, can someone give a synopsis?
_________________________
Giddy up.
|
Return to Top
|
|
|
|
#1750388 - 10/18/12 05:57 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ComplianceGrl15
|
10K Club
Joined: May 2004
Posts: 10,124
Way, way south.
|
Q: Do banks now HAVE to accept private flood insurance, or is it merely OK to accept private flood insurance?
I have researched and have gotten opposing viewpoints, thanks.
_________________________
Giddy up.
|
Return to Top
|
|
|
|
#1755854 - 11/07/12 02:58 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ComplianceGrl15
|
10K Club
Joined: Jul 2001
Posts: 84,333
Galveston, TX
|
I think the white paper is jumping the gun just slightly. I am not aware of any guidance that has been issued on any of these issues by the regulators or the NFIP.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#1757938 - 11/14/12 06:19 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
Sewanee, CRCM
|
Power Poster
Joined: Aug 2006
Posts: 4,266
Chillin an grillin
|
Thanks sewanee, after reading the whitepaper, I was going to start amending our P&P's. Glad that the ABA laid this out more clearly.
_________________________
HMDAHMDAHMDAHMDAHMDAHMDA
|
Return to Top
|
|
|
|
#1762610 - 11/29/12 10:29 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ComplianceGrl15
|
Power Poster
Joined: Jan 2004
Posts: 2,795
Guess
|
So here's a wrinkle for all. Chase is requiring that the language on availability of private flood insurance be in a notice given to customers starting for applications taken 1/1/2013. Even when I pointed out that the notice is not yet effective, they said that "the Act has passed and we expect you to be compliant." So, I asked to see a copy of the noitce they are giving their customers...so far, crickets...what kind of *%^)(*&*& compliance attorneys do they have working for them that don't understand that just because an Act was passed does not mean the provisions must immediately be complied with?!
_________________________
Sorry, did I just use my outside voice?
|
Return to Top
|
|
|
|
#1762800 - 11/30/12 03:50 PM
Re: Biggert-Waters Flood Insurance Reform Act of 2012
ComplianceGrl15
|
Power Poster
Joined: Jan 2004
Posts: 2,795
Guess
|
I don't see anything in the Act that the notice regarding availability of private flood insurance needs to be signed, is that correct? Thanks!
_________________________
Sorry, did I just use my outside voice?
|
Return to Top
|
|
|
|
|
|