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OCC 2008-7
OCC BULLETIN

Comptroller of the Currency
Administrator of National Banks

    


Subject: Flood Disaster Protection Act
Description: Revised Interagency Questions and Answers Regarding Flood Insurance

Date: March 21, 2008

TO: Chief Executive Officers and Compliance Officers of All National Banks, Department and Division Heads, All Examining Personnel, and Other Interested Parties

On March 21, 2008, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision, the National Credit Union Administration, and the Farm Credit Administration (the agencies), published in the Federal Register proposed “Interagency Questions and Answers Regarding Flood Insurance” (2008 Interagency Questions and Answers). These proposed 2008 Interagency Questions and Answers are intended to assist regulatory personnel, financial institutions, and the public in understanding the flood insurance regulation.

The agencies are proposing new questions and answers, as well as substantive and technical revisions to existing Interagency Questions and Answers that were published in 1997. Among the changes the agencies are proposing are substantive modifications to questions and answers previously adopted in the 1997 Interagency Questions and Answers pertaining to construction loans and condominiums. The agencies are also proposing the introduction of new questions and answers in a number of areas, including second lien mortgages, the imposition of civil money penalties, and loan syndications/participations. Finally, the agencies are proposing to revise and reorganize certain of the existing questions and answers to clarify areas of potential misunderstanding and to provide clearer guidance to users.

It is the intention of the agencies, that after public comment has been received and considered, any final revised Interagency Questions and Answers will supersede the 1997 Interagency Questions and Answers and supplement other guidance or interpretations issued by the agencies and the Federal Emergency Management Agency.

Public comment is invited on the proposed new and revised questions and answers, as well as on other issues and concerns regarding compliance with the federal flood insurance statutes and regulations, by May 20, 2008.

Interested parties are encouraged to review the attached 2008 Interagency Questions and Answers. For more information, please contact Pamela Lea Mount, National Bank Examiner, Compliance Policy, at (202) 874-4428; or Margaret Hesse, Special Counsel, Community and Consumer Law Division, at (202) 874-5750.


                       /signed/                                                
Ann F. Jaedicke
Deputy Comptroller for Compliance Policy

 

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