CUNA submitted comments Monday to NCUA on the proposed Interagency Questions and Answers Regarding Private Flood Insurance. These proposed questions and answers follow a set from July 2020 issued by the same agencies.

“Once both the July Proposed Q&As and these Proposed Q&As have been finalized, CUNA suggests NCUA include the combined interagency guidance as an Appendix to its implementing regulations in Part 760,” the letter reads. “This will ensure the guidance can be easily located and used by credit union staff in years to come. We appreciate the Agencies’ review of the existing Q&As, improvements on their organization and clarity, and the creation of new guidance material to further support credit unions in implementing the flood insurance requirements.

“Over time and as the use of private flood insurance becomes more common, additional issues may arise for credit unions in implementing these rules and guidance, it adds. “CUNA will share these issues with the NCUA and the Agencies, which should then update and amend the Proposed Q&A guidance at some time in the future to provide additional clarity.”

CUNA supported last year’s review of questions and answers, and offered several suggestions for improvements.