CUNA supports the joint interagency review of flood insurance questions and answers in comments filed Tuesday but offers several suggestions for improvements.
The proposal includes the introduction of new questions and answers on the escrow of flood insurance premiums, force placement of flood insurance and the detached structures exemption.
It would also create a new system of designation for the questions and answers. They would be designated by the category to which it belongs and then designated in numerical order for that particular category under the proposed system, rather than numbering them successively through all the categories.
“We appreciate the changes to restructure and re-designate the Q&As. We agree that doing so will promote ease of reference,” the letter reads. “Further, we support these changes since this numbering system will enable the Agencies to add or delete Q&As in the future without significantly renumbering or reorganizing them, which will aid lenders as they refer to the Q&As as a compliance resource.