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Financial Institution Letter

Flood Insurance: Proposed Revisions to Interagency Questions and Answers

June 26, 2020  |  FIL-67-2020


The FDIC, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the National Credit Union Administration, and the Farm Credit Administration (Agencies) are issuing proposed new and revised Interagency Questions and Answers Regarding Flood Insurance (Interagency Questions and Answers). The proposal seeks to incorporate amendments to federal flood insurance laws regarding the escrow of flood insurance premiums, the detached structure exemption, and force placement of insurance into the Interagency Questions and Answers. The document is intended to help lenders meet their responsibilities pursuant to the federal flood insurance laws that were last updated in 2011.

A copy of the Proposed Revisions can be found on the FDIC's website.

Statement of Applicability to Institutions Under $1 Billion in Total Assets: This Financial Institution Letter (FIL) applies to all FDIC-supervised financial institutions.


  • The Interagency Questions and Answers provide information to assist financial institutions in meeting their federal flood insurance compliance responsibilities, and to increase public understanding of flood insurance requirements.
  • Proposing the new and revised Interagency Questions and Answers also would address a commitment to provide the banking industry with additional information on flood insurance requirements made in the Federal Financial Institutions Examination Council’s Economic Growth and Regulatory Paperwork Reduction Act Report to Congress (March 2017).
  • The Agencies are proposing new questions and answers in a number of areas, including the escrow of flood insurance premiums, the detached structures exemption, and force placement of flood insurance. Other proposed questions and answers are revised to provide additional flood insurance compliance information to supervised institutions.
  • The Agencies are also proposing to reorganize the Interagency Questions and Answers to make it easier to find information related to technical flood insurance topics. For example, the proposed questions and answers are organized by subject matter and the general order of the flood insurance application process. There is also a new numbering system.
  • Comments on the NPR need to be received by the FDIC on or before 60 days after publication in the Federal Register.
  • In addition, the Agencies are drafting new Interagency Questions and Answers Regarding Flood Insurance related to the 2019 private flood insurance final rule and will propose these Interagency Questions and Answers at a later date.



FDIC-Supervised Institutions

Suggested Routing:

Chief Executive Officer
Chief Credit Officer
Chief Risk Officer
Chief Compliance Officer

Related Topics:

Homeowner Flood Insurance Affordability Act of 2014

Biggert-Waters Flood Insurance Reform Act of 2012

Flood Disaster Protection Act of 1973