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#1784431 - 02/08/13 09:53 PM 2007 Flood guidance rescinded
AngelMae CRCM Offline
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Indiana
I haven't seen anything here on this, but we just saw this notice from FEMA.
http://www.fema.gov/library/viewRecord.do?id=2954

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Flood Compliance
#1784449 - 02/08/13 10:14 PM Re: 2007 Flood guidance rescinded AngelMae CRCM
Andy_Z Offline
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I know I've been in discussions with others, but I haven't discussed it here. I think it caught many off guard and leaves us now with fewer resources. It's hard to use something as guidance that is rescinded even when a lot is still good info.
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#1784481 - 02/08/13 11:26 PM Re: 2007 Flood guidance rescinded AngelMae CRCM
rlcarey Online
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I think they had no choice but to rescind it, but I disagree and think that it is still a valuable resource, just not in the specific areas which were made obsolete by the BW Act. Of course, the interagency Q&A addresses, from the primary regulator perspective, most everything that was in the Manual.
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#1784514 - 02/09/13 01:16 PM Re: 2007 Flood guidance rescinded AngelMae CRCM
Kathleen O. Blanchard Offline

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Ii wish they had rescinded just certain sections. A blanket rule that tosses the good with the bad does this type of thing.
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#1784931 - 02/11/13 10:34 PM Re: 2007 Flood guidance rescinded rlcarey
Sewanee, CRCM Offline
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TN
One area bank contacted their regulator (FDIC) and were told that since the guidance was rescinded it was to no longer be used. They were directed to the Interagency Q&As until further information comes from either FEMA or the regulators.

I'm OCC, and have heard nothing from them.
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#1784967 - 02/12/13 03:26 AM Re: 2007 Flood guidance rescinded AngelMae CRCM
rlcarey Online
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"it was to no longer be used"

Used for what? It was only a resource for information to begin with. Most of that information has not changed. I have never seen a regulator cite the MPFIG as a source for a violation anyway. If someone wants basic information, it is still a good source, barring the changes that the new legislation impacts.
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#1786993 - 02/16/13 12:07 AM Re: 2007 Flood guidance rescinded AngelMae CRCM
Princess Romeo Offline

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Does that mean that flood insurance requirements are just too difficult for FEMA to figure out?

The issue that I see is that "some" examiners could use this to start making up their own interpretations in order to gin up the CMP's.
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#1786995 - 02/16/13 02:20 AM Re: 2007 Flood guidance rescinded AngelMae CRCM
KPOC Offline
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Greater Boston Area
Just went to conference where this was addressed. MPFI is out. Manual and Act itself are still useful. Prudential regulators have no authority over FEMA's informational materials. NFIP is a flood plain management program, not regulation. Regulaors can enforce regulations, e.g., part 339 or Reg. H. Nothing has changed from a regulatory perspective, except the CMPs.

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#1787009 - 02/16/13 02:15 PM Re: 2007 Flood guidance rescinded AngelMae CRCM
rlcarey Online
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Does that mean that flood insurance requirements are just too difficult for FEMA to figure out?

No, it means that the flood insurance program was significantly changed by the Biggers Waters Act and they need time to incorporate those changes into a new manual.

Even the bank have been given a year on the new regulations to get their house in order. I think we need to cut the NFIP a little slack here while they figure out what specific things they need to get changed.
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#1787064 - 02/17/13 07:48 PM Re: 2007 Flood guidance rescinded AngelMae CRCM
KPOC Offline
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Greater Boston Area
I think everyone knows this but I want to make sure: the Flood Insurance Manual has NOT been rescinded. The Mandatory Purchase of Flood Insurance Guidelines is the only document to be rescinded. I see both documents being referenced and I just want to make sure everyone is clear...Manual is still being used.
Last edited by KPOC; 02/17/13 07:49 PM.
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#1787174 - 02/19/13 02:50 PM Re: 2007 Flood guidance rescinded AngelMae CRCM
banker-12 Offline
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Do we need to start increasing the coverage for multifamily residential properties to $500,000 now?

Does does not include condo's correct? We still follow the # of units X $250,000 as the maximum coverage allowed, correct?

thanks,

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#1787471 - 02/20/13 03:01 AM Re: 2007 Flood guidance rescinded AngelMae CRCM
rlcarey Online
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