NFDA Offers Comments to Proposed Rulemaking re: Loans Secured by Property Located in Special Flood Hazard Areas

Five federal regulatory agencies issued a joint notice of proposed rulemaking on October 11, 2013 to amend regulations pertaining to loans secured by property located in special flood hazard areas. The proposed rule would implement certain provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert-Waters) with respect to private flood insurance, the escrow of flood insurance payments, and the forced-placement of flood insurance.

NFDA offered comments to the five regulatory agencies on the Proposed Flood Insurance Rule. Our comments support and are consistent with positions offered by lender associations (MBA, ABA, and CBA) and insurance associations (AIA and ABIA). Several NFDA member companies expressed the need for a publication to replace the rescinded Mandatory Purchase of Flood Insurance Guidelines, and that request was stressed in the NFDA comments.

NFDA Comments re Loans in Areas Having Special Flood Hazards

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