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#1879134 - 12/16/13 10:55 PM Major June 1, 2014 NFIP changes
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,225
Galveston, TX
The bulk of the remainder of the BW-12 changes are going to be effective June 1, 2014:


* New maximum limits for Other Residential buildings under the Standard Flood Insurance Policy (SFIP) General Property Form;
* Revised non-primary residence definition;
* Revised deductible amounts and changes to the minimum deductible;
* Clarification on the maximum coverage available for commercial properties and new process to ensure that only one policy per building is being insured under the NFIP;
* New declaration page requirement for Pre-FIRM subsidized policies;
* Clarification on subsidy elimination and grandfathering procedures;
* Revised SFIP forms.

http://www.nfipiservice.com/Stakeholder/FEMA2/W-13070.html
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Flood Compliance
#1884087 - 01/07/14 11:03 PM Re: Major June 1, 2014 NFIP changes rlcarey
DAniya Offline
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Hawaii
Regarding the increased "other residential" coverage - Do you or anyone else know if we will need to have existing borrowers increase their coverage by 06/01/14? or upon policy renewal? Looks like the lenders have to send a notification informing the policyholders that the coverage is available, but I didn't see any lender notice.

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#1884094 - 01/07/14 11:25 PM Re: Major June 1, 2014 NFIP changes rlcarey
rlcarey Online
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rlcarey
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Galveston, TX
I would think that lenders are going to need to review their loan portfolios that currently require flood insurance and determine which borrowers are going to be impacted by the increased policy limits and whether or not the new limits will impact the minimum amount of insurance that is required. On June 1, lenders need to have their 45 days to these borrowers ready to go. As on June 1, the lenders will be on notice that the borrowers are underinsured.
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#1884436 - 01/08/14 10:36 PM Re: Major June 1, 2014 NFIP changes rlcarey
DAniya Offline
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Thanks. Appreciate the response!
Last edited by DAniya; 01/08/14 10:37 PM.
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#1887559 - 01/16/14 05:29 PM Re: Major June 1, 2014 NFIP changes rlcarey
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In the changes to the Flood Insurance Program, the summary refers to "insurers" when it discusses having to send out notices at least 90 days prior. Are those notices required to be sent by the Bank or the Flood Insurance Agent? Who is the "insurer"?

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#1887564 - 01/16/14 05:31 PM Re: Major June 1, 2014 NFIP changes rlcarey
rlcarey Online
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rlcarey
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Galveston, TX
The bank surely is not the "insurer".
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#1887898 - 01/17/14 02:17 PM Re: Major June 1, 2014 NFIP changes rlcarey
complyorelse Offline
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Is there any requirement to escrow ALL existing and new loans for flood if we don't escrow them for taxes and insurance? We currently only escrow our residential portfolio but not our commercial portfolio.

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#1887904 - 01/17/14 02:26 PM Re: Major June 1, 2014 NFIP changes rlcarey
rlcarey Online
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rlcarey
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Galveston, TX
Your questions are addressed within the proposed rules:

http://www.federalreserve.gov/newsevents/press/bcreg/20131011a.htm
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#1887908 - 01/17/14 02:31 PM Re: Major June 1, 2014 NFIP changes rlcarey
JWills, CRCM Offline
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I believe loans that are an extension of credit for a business, commercial or agricultural purposes even if they are secured by residential real estate are exempt.
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#1887923 - 01/17/14 02:43 PM Re: Major June 1, 2014 NFIP changes rlcarey
rlcarey Online
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rlcarey
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Awww - you ruined the surprise. I wanted them to read the proposed regs like the rest of us had too smile
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#1887927 - 01/17/14 02:47 PM Re: Major June 1, 2014 NFIP changes rlcarey
JWills, CRCM Offline
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JWills, CRCM
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Sorry Randy!
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#1888333 - 01/17/14 10:30 PM Re: Major June 1, 2014 NFIP changes JWills, CRCM
Reads Regs Offline
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FEMA came out with an addendum to the bulletin. http://www.nfipiservice.com/Stakeholder/pdf/bulletin/w-14001.pdf
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#1888339 - 01/17/14 10:40 PM Re: Major June 1, 2014 NFIP changes rlcarey
rlcarey Online
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rlcarey
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Yeah - I already wrote them about it.

I asked them how my 96 year old mother-in-law was going to prove that the house she lives in is her primary residence. You have to prove it with one of six specific documents. The first five are out of the question:

• Driver’s license
• Automobile registration
• Proof of insurance for a vehicle
• Voter’s registration
• Documents showing where children attend school; or
• Homestead Tax Credit Form for Primary Residence.

I’m not even sure what the definition of the sixth document might be and whether or not that is a possibility.
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#1891401 - 01/28/14 09:04 PM Re: Major June 1, 2014 NFIP changes rlcarey
complyorelse Offline
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To be clear, the escrow provisions are not final at this point? Any indication as to when they will be?

Thank you.

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#1891478 - 01/28/14 11:40 PM Re: Major June 1, 2014 NFIP changes rlcarey
rlcarey Online
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rlcarey
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Comments closed on the proposal on December 10, 2013. Your guess is as good as ours.
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#1892067 - 01/30/14 04:25 PM Re: Major June 1, 2014 NFIP changes rlcarey
complyorelse Offline
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Thanks.

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#1892124 - 01/30/14 05:42 PM Re: Major June 1, 2014 NFIP changes rlcarey
HRH Okie Banker Offline
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Joined: Jan 2003
Posts: 3,070
Oklahoma
Originally Posted By: rlcarey
The bulk of the remainder of the BW-12 changes are going to be effective June 1, 2014:


* New maximum limits for Other Residential buildings under the Standard Flood Insurance Policy (SFIP) General Property Form;
* Revised non-primary residence definition;
* Revised deductible amounts and changes to the minimum deductible;
* Clarification on the maximum coverage available for commercial properties and new process to ensure that only one policy per building is being insured under the NFIP;
* New declaration page requirement for Pre-FIRM subsidized policies;
* Clarification on subsidy elimination and grandfathering procedures;
* Revised SFIP forms.

http://www.nfipiservice.com/Stakeholder/FEMA2/W-13070.html


crazy cry

At least 90 days prior to June 1, 2014, insurers must send the attached sample letter (see Attachment C) to all Other Residential policyholders to inform them of the new maximum limits. Insurers must also include a message on the Renewal Notice advising affected policyholders that higher limits are available.
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#1933622 - 06/18/14 03:57 PM Re: Major June 1, 2014 NFIP changes rlcarey
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Joined: Jun 2009
Posts: 89
Is there an implementation date for section 100239 of the BWA (specifically the notice to borrower about private insurance)?

Also, is this notice really any different than the notice already required by Reg H 208.25(g) (forced placement of flood insurance)?

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#1934274 - 06/20/14 12:56 PM Re: Major June 1, 2014 NFIP changes rlcarey
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bump...

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#1934689 - 06/22/14 11:40 AM Re: Major June 1, 2014 NFIP changes rlcarey
rlcarey Online
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rlcarey
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Galveston, TX
It was in the proposed rule making that has been put on hold.
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#1935862 - 06/26/14 06:55 PM Re: Major June 1, 2014 NFIP changes rlcarey
MPComply Offline
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MPComply
Joined: Jun 2011
Posts: 19
New York
Ellie Mae is updating the disclosure to reflect the change, but as I understand it, it isn't in effect yet. Correct?

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