Final flood Q&As reflect CUNA-sought clarifications

May 12, 2022

NCUA and other federal financial regulators issued a joint rule finalizing significant changes to Flood Insurance Questions and Answers made by the Biggert-Waters Flood Insurance Reform Act of 2012 and the Homeowner Flood Insurance Affordability Act of 2014. The final rule—effective immediately—contains several CUNA-requested clarifications.

The update revises and reorganizes questions and answers originally published in 2009 and 2011, and includes several new questions and answers responsive to the changes in federal law. The final rule consolidates two proposed rules issued in 2020 and 2021.

CUNA-sought clarifications include:

  • Clear preamble language specifying that while flood insurance discrepancies can be addressed at any time, they are only required to be addressed at the time of a potential loss.
  • Additional  language clarifying what constitutes a “reasonable time” for providing the Notice of Special Flood Hazards, including a specification that 10 calendar days before closing is reasonable.
  • Additional language regarding the application of the small lender exceptions to better aid credit unions in understanding its application and intent.

Additional details can be found on CUNA’s CompBlog and Removing Barriers Blog.