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#1879134 - 12/16/13 10:55 PM
Major June 1, 2014 NFIP changes
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10K Club
Joined: Jul 2001
Posts: 83,225
Galveston, TX
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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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#1884087 - 01/07/14 11:03 PM
Re: Major June 1, 2014 NFIP changes
rlcarey
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New Poster
Joined: Oct 2013
Posts: 17
Hawaii
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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
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10K Club
Joined: Jul 2001
Posts: 83,225
Galveston, TX
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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
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New Poster
Joined: Oct 2013
Posts: 17
Hawaii
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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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100 Club
Joined: Jan 2004
Posts: 164
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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
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10K Club
Joined: Jul 2001
Posts: 83,225
Galveston, TX
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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
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Gold Star
Joined: Nov 2007
Posts: 448
U.S.
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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
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10K Club
Joined: Jul 2001
Posts: 83,225
Galveston, TX
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#1887908 - 01/17/14 02:31 PM
Re: Major June 1, 2014 NFIP changes
rlcarey
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Diamond Poster
Joined: May 2013
Posts: 1,781
The Mitten State
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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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Nonsense wakes up the brain cells.
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#1887923 - 01/17/14 02:43 PM
Re: Major June 1, 2014 NFIP changes
rlcarey
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10K Club
Joined: Jul 2001
Posts: 83,225
Galveston, TX
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Awww - you ruined the surprise. I wanted them to read the proposed regs like the rest of us had too
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#1887927 - 01/17/14 02:47 PM
Re: Major June 1, 2014 NFIP changes
rlcarey
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Diamond Poster
Joined: May 2013
Posts: 1,781
The Mitten State
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Sorry Randy!
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Nonsense wakes up the brain cells.
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#1888333 - 01/17/14 10:30 PM
Re: Major June 1, 2014 NFIP changes
JWills, CRCM
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Diamond Poster
Joined: Nov 2004
Posts: 2,307
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.
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#1888339 - 01/17/14 10:40 PM
Re: Major June 1, 2014 NFIP changes
rlcarey
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10K Club
Joined: Jul 2001
Posts: 83,225
Galveston, TX
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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
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Gold Star
Joined: Nov 2007
Posts: 448
U.S.
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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
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10K Club
Joined: Jul 2001
Posts: 83,225
Galveston, TX
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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
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Gold Star
Joined: Nov 2007
Posts: 448
U.S.
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#1892124 - 01/30/14 05:42 PM
Re: Major June 1, 2014 NFIP changes
rlcarey
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Power Poster
Joined: Jan 2003
Posts: 3,070
Oklahoma
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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 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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Just working here until I get my letter from Hogwarts.
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#1933622 - 06/18/14 03:57 PM
Re: Major June 1, 2014 NFIP changes
rlcarey
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Member
Joined: Jun 2009
Posts: 89
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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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Member
Joined: Jun 2009
Posts: 89
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#1934689 - 06/22/14 11:40 AM
Re: Major June 1, 2014 NFIP changes
rlcarey
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10K Club
Joined: Jul 2001
Posts: 83,225
Galveston, TX
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It was in the proposed rule making that has been put on hold.
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