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#1903989 - 03/10/14 10:02 PM
Bank Required to have Written Policy on Flood
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Platinum Poster
Joined: Oct 2004
Posts: 822
midwest
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Is a bank required to have a written policy regarding compliance with the flood disaster protection act requirements? If so, where is the requirement outlined in the regulation/act? Thanks.
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#1903999 - 03/10/14 11:08 PM
Re: Bank Required to have Written Policy on Flood
complygirl
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10K Club
Joined: Jul 2001
Posts: 83,364
Galveston, TX
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Not that I am aware of. Sufficient written procedures would probably suffice.
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#1912090 - 04/04/14 10:24 PM
Re: Bank Required to have Written Policy on Flood
complygirl
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10K Club
Joined: Jul 2001
Posts: 83,364
Galveston, TX
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Just received MRA from OCC for lack of policy.
Unless your institution was also cited for flood compliance weaknesses, my first call would be the ombudsman asking them to help procure a citation that indicates the lack of a flood insurance policy (when you have no choice in compliance) is a requirement. Board and management policies are to establish how a bank is going to handle something in which there are options. If there are no options, then you might call it a policy, but it will be nothing but procedures unless you plan on just having the board pass a policy that reads like the regulation.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1912126 - 04/07/14 12:36 PM
Re: Bank Required to have Written Policy on Flood
Kathleen O. Blanchard
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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A few years ago, the OCC cited us for not having a written flood compliance policy. They acknowledged that our procedures were fine, they could find no violations, and we were doing everything that we were supposed to be doing, but we needed to have a written policy.
I asked the examiner if we were required to have a specific written policy for each of the "alphabet regulations", and why we needed a policy if the exam team itself admitted that our procedures were working. He was not at all pleased with my questions.
We wrote a flood policy.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1912132 - 04/07/14 01:09 PM
Re: Bank Required to have Written Policy on Flood
complygirl
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Joined: Nov 2002
Posts: 20,656
The Swamp
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See now that just chaps my cheeks. Unless a policy is specifically required, having one for the sake of having one is just ridiculous. Good procedures is a different story.
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My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#1912155 - 04/07/14 01:41 PM
Re: Bank Required to have Written Policy on Flood
RR Joker
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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I absolutely agree. Unfortunately, I was the only member of senior management that wanted to challenge the demand, and I was told to get the policy written ASAP.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1912593 - 04/08/14 02:36 PM
Re: Bank Required to have Written Policy on Flood
complygirl
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Joined: Oct 2000
Posts: 40,086
Cape Cod
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I strongly believe in written procedures, particularly with the complexity of compliance with flood insurance requirements. Well-written procedures provide credibility as to your process, uniformity of the process, and a good training tool for the inevitable newbie to the process.
But the only "policies" that I think are necessary in this area are those covering the real estate securing your loan portfolio.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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