FDIC Federal Register Citations

From: Kelly Foster
Sent: Friday, March 21, 2008 2:17 PM
To: Comments
Subject: Joint Notice - Flood Insurance - RIN 3064-ZA00 

Question 72 states that a lender cannot rely on a previous Notice if it is less than seven years old and it is the same property, same borrower and same lender.

Page 34 of the Mandatory Purchase of Flood Insurance Guidelines state that the purpose of the Notice is to advise the borrower about the Federal flood insurance coverage requirements and whether Federal disaster relief assistance is available in the location.  If there has been no map change, a previously provided Notice would have already accomplished this for the property in question.  There seems little benefit to the borrower (particularly those who are already maintaining flood insurance) to provide the information contained in this Notice again, while it penalizes the lender who fails to provide it.