Skip to content
BOL Conferences
Learn More - Click Here!

New Reply Thread Options
#1762344 - 11/29/12 05:56 PM Biggers-Waters Act
Anonymous
Unregistered

I see that the OCC has implemented the increased fines for flood violations per Biggers-Waters. Has the increased coverage for multi-family dwellings also become effective?

Return to Top Reply Quote Quick Reply Quick Quote
#1762396 - 11/29/12 06:40 PM Re: Biggers-Waters Act Anonymous
Bullseye Offline
Platinum Poster
Bullseye
Joined: Jan 2004
Posts: 968
Yes. My understanding is that the increased penalties and the increased coverage for 5+ family dwellings took effect the day it was signed. The remainder of the provisions require regulations to be written.

Return to Top Reply Quote Quick Reply Quick Quote
#1763725 - 12/04/12 06:31 PM Re: Biggers-Waters Act Anonymous
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Based on the CMP announcements from the FDIC and OCC, it appears that those agencies did not applied the higher CMP amounts for exams occurring before they published their new penalty amounts rules.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top Reply Quote Quick Reply Quick Quote
#1763893 - 12/04/12 11:29 PM Re: Biggers-Waters Act Anonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
They normally don't even apply the full $385, so it will be interesting to see if they actually go up.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top Reply Quote Quick Reply Quick Quote
#1764198 - 12/05/12 08:10 PM Re: Biggers-Waters Act Anonymous
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I stand corrected. The OCC and Fed have published their quadrennial inflation adjustments to CMP amounts and changed the Flood penalty from $385 to $2000; the FDIC board is approving their adjustments list at their 12/11/12 meeting.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top Reply Quote Quick Reply Quick Quote
#1764259 - 12/05/12 09:31 PM Re: Biggers-Waters Act John Burnett
OnTheEdge Offline
Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
I am sorry to interupt this serious conversation, but does anyone else see the humour in the name of this Act. "Biggers-Waters" related to Flood Insurance.
_________________________
The opinions expressed are mine and do not necessarily reflect those of my employer.

Return to Top Reply Quote Quick Reply Quick Quote
#1764360 - 12/06/12 12:43 PM Re: Biggers-Waters Act Anonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Actually, the formal title is: “Biggert-Waters Flood Insurance Reform and Modernization Act of 2012”.

It is not Biggers.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top Reply Quote Quick Reply Quick Quote
#1764472 - 12/06/12 02:46 PM Re: Biggers-Waters Act rlcarey
OnTheEdge Offline
Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
Thanks for the correction, but it somehow still seems a bit funny to me.
_________________________
The opinions expressed are mine and do not necessarily reflect those of my employer.

Return to Top Reply Quote Quick Reply Quick Quote
#1764672 - 12/06/12 06:17 PM Re: Biggers-Waters Act Anonymous
West Coast Comp Offline
Gold Star
West Coast Comp
Joined: Jun 2010
Posts: 350
Lost in the rain.
I'm with you Lucky...it's at least apropos
_________________________
Where I go there I am. smile

Return to Top Reply Quote Quick Reply Quick Quote
#1764753 - 12/06/12 07:22 PM Re: Biggers-Waters Act Anonymous
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
I just don't see the examiners keeping the penalties low. These CMPs go to FEMA, not Treasury (and maybe that is part of the answer) but FEMA is worse than broke. Charging penalties for violations makes more "cents" than all the fees they are assessing or requiring banks to reduce. You can only take so much from each bank, why not hit the violators harder. Anyway, each agency has published the new rates and that may have been the hurdle they were waiting for.

This last month, Nov for October, there was a very small number of flood and HMDA penalties. I was surprised.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top Reply Quote Quick Reply Quick Quote
Quick Reply:
HTML is disabled
UBBCode is enabled




Moderator:  MagicCity, P*Q, Truffle Royale