Does anyone have a Flood Policy that they would be willing to share? We have extensive procedures, but internal audit is recommending a policy. Thanks

Are you an ABA member? Their website has sample policies.

No, if only.

Policy:

The Bank will comply with all aspects of the flood insurance regulations. Management is hereby delegated to establish adequate policies to comply with current regulations and guidelines.

See if that makes your auditor happy and then ask them to point out what regulatory guidance requires a flood policy.

I agree with Randy in that there is no regulatory requirement for a flood policy. Now with that said several of the regulators, especially the FDIC, went on a policy frenzy a few years ago. We put the following in our loan policy as a result of that frenzy:

The bank must perform a Flood Zone Determination for all loan requests to be secured by improved real estate prior to loan closing to determine if it lies in a flood zone. If it is determined that the property is located in a flood zone then the bank must provide the borrower the Notice of Special Flood Hazard and Availability of Federal Disaster Relief Assistance within a reasonable time before closing and require flood insurance in an amount to meet the minimum coverage requirements outlined in the regulation and with the bank listed as the loss payee.