I attended a seminar hosted by Jack in December. He outlined the new provision of the Biggert Waters Act and one of them specified that multifamily properties were eligible for $500,000 in flood insurance coverage effective the date the act was signed in July 2012 (up from $250,000). We have a multifamily property in an SFHA and the insurance agent is insistent that this isn't in effect yet and that he's talked to the NFIP and they don't know when it will be available.

Am I off base or is he? Right now the only thing I know to do is force-place at the end of the 45 day notice.

Latest I heard from a Compliance Conference Call last week was that it was not in effect yet......Couple of points made were...regs would have to be written plus FEMA would need to update.....even on the minimum deductables CFPB has to write rules for that.....Alot on Bigget Waters was still waiting on guidance......or this is what my notes are on it at this stage of the game.

Yeah, I looked everywhere and couldn't find anything on this. FEMA has not released anything.

I did a webinar done by NFIP last week and they said that they will have to develop another policy type and that they haven't done this part yet. They are currently focused on the subsidized premium changes right now.

I think that Jack is technically correct in that the change had no later effective date in the law, thus making it effective at the time the bill was changed, but the NFIP hasn't gotten to that part yet so we can't do anything about it.

My thought is that you have a policy that is the max available from the NFIP at this time, regardless of changes to the law.