Hi! Several communities in our area have received notice of suspension from the NFIP for non-compliance. I am not sure what impact that has on us, but I assume it is HUGE. I found this information on the web:

Effects of Suspension

Bank customers, as residents or purchasers of flood insurance, face problems if communities are suspended. A community that is suspended from the NFIP (or does not join or has withdrawn from the program) can result in the following sanctions:
No resident will be able to purchase a flood insurance policy.
Existing flood insurance policies will not be renewed.
No Federal grants or loans for development may be made in identified flood hazard areas under programs administered by Federal agencies such as HUD, EPA, and SBA.
No Federal disaster assistance may be provided to repair insurable buildings located in identified flood hazard areas for damage caused by a flood.
No Federal mortgage insurance or loan guarantees may be provided in identified flood hazard areas. This includes policies written by FHA, VA, and others.
Federally insured or regulated lending institutions, such as banks and credit unions, must notify applicants seeking loans for insurable buildings in flood hazard areas that there is a flood hazard and that the property is not eligible for Federal disaster relief.

But, for existing loans, they would be able to purchase private flood insurance, correct? For a new loan applicant, how does private flood insurance change the above? I am thinking we notify an applicant they are in a SFHA, that no federal flood insurance is available and they will be required to purchase private flood insurance? Does FHA and VA accept private flood policies prior to July 1, 2019?

Notice of suspension or a notice that they are to be suspended? Keep an eye on the Community Status Book. https://www.fema.gov/national-flood-insurance-program-community-status-book

It is pretty usual for a community to not fix their deficiencies by the time of the deadline for suspension.

They are to be suspended February 15, 2019.

Oh - and if the community is suspended, then NFIP flood insurance is not available - private insurance would be a risk decision at that point as the loan would no longer be a designated loan.

(5) Designated loan means a loan secured by a building or mobile home that is located or to be located in a special flood hazard area in which flood insurance is available under the Act.

Excellent point! I am in panic mode right now, so I didn't think of that, though I would think we would want private flood insurance for these properties. I am guessing, as you stated, the problem will be fixed but probably not before Feb 15, 2019, so I am trying to figure out how we manage this- even if temporarily. I have never had this happen before where I work and I am new here, so there are no procedures, etc. (I will be writing some though!)

Take a deep breath and check the status book next week. There are only 11 communities currently suspended in all of IL

Thank you!

We had a community that was on the suspension list a couple years ago. We made a couple calls, and it turned out that the county planning department didn't realize some paperwork hadn't been submitted. They were glad we alerted them, and the matter was resolved within a couple days - the work had been done, just wasn't submitted.

Thank you mtngrrl for the information. I might check into that!

Ok so I am back with another question. Today, I checked community status book and all of the communities have a > next to them which means "Date of Current Effective Map is after the Date of This Report" - does that mean they are not suspended and everything is ok - FEMA just needs to update their map?? Is there anything we need to do with these loans during this time? Why can't they just say- oops! We jumped the gun, these communities are just fine. Carry on!"

LOL - It is not next week yet. Check after 02/15 and if they not in the book with a "(S)" designation, you have nothing to worry about. Likely, they were pending something from the communities - like a formal acceptance of the new maps.

Ah-ha! As always, thanks for talking me off the ledge, Randy!

The thing that ticks me off is that the boilerplate language that FEMA includes in its Federal Register notices of suspension indicates that, "If the Federal Emergency Management Agency (FEMA) receives documentation that the community has adopted the required floodplain management measures prior to the effective suspension date given in this rule, the suspension will not occur and notification of this will be provided by publication in the Federal Register on a subsequent date." I have never seen a "never mind" notice in the FR.

The next sentence in that boilerplate, though, does direct the reader to the Community Status Book pages.

Yes, I agree, John. Today when I checked the Community Status Book all the maps had been updated and no one was suspended. It was a little frustrating for me because if I did nothing and the communities were suspended, we would have been scrambling around. As it ended up, I did a bunch of scrambling- but at least I will be better prepared next time.

Reviving this thread with a question: If you make a loan in one of those communities while they are suspended and don't get flood insurance at that time, what happens when the suspension is over? Do you have to require flood then (45 day letter and all) or do you wait for a MIRE event to do anything?

Once insurance becomes available it would be treated the same as them being remapped if you are aware of it.

Thank you, rl. It made sense that it would work that way but common sense doesn't always win with compliance