Federal Deposit Insurance Corporation 12 CFR Part 339 Interpretations The Federal Financial Institutions Examination Council (FFIEC) issued interpretations (in a question and answer format) on July 16, 1997. AN UPDATE WAS PUBLISHED June 30, 2009 and is 35 pages!!!! Another update was issued September 30,2011 This is the link for the 1997 & 2009: and is 38 pages., Link to October 2011 FAQ’s: OVERVIEW AND KEY REQUIREMENTS FUNDAMENTAL #1 – Purpose - The purpose of the laws and the regulations is to: Provide subsidized insurance to flood-prone areas; Require local jurisdictions to enact land use and flood control measures; Require flood insurance for loans secured by a building or a mobile home located in a special flood hazard area in a participating community; and Provide notice of the risk of flooding and the availability of subsidized flood insurance to owners of buildings and mobile home located in special flood hazard areas. NOTE: This is not a compliance protection law. The purpose of the typical “consumer” law is to protect the for flood insurance for residential AND GOVERNMENT’S program commercial property. Lenders have been to enforce the provisions. IT IS “deputized” COLLATERAL DRIVEN NOT PURPOSE DRIVEN!! – COVERAGE OF REGULATIONS General Rule The regulations apply when making, increasing, renewing or extending a loan: (MIRE) Secured by a building or a mobile home Located or to be located in an area determined by the Director of the Federal Emergency Management Agency to have special flood hazards.
Federal Deposit Insurance Corporation 12 CFR Part 339 Interpretations The Federal Financial Institutions Examination Council (FFIEC) issued interpretations (in a question and answer format) on July 16, 1997. AN UPDATE WAS PUBLISHED June 30, 2009 and is 35 pages!!!! Another update was issued September 30,2011 and is 38 pages., This is the link for the 1997 & 2009: Link to October 2011 FAQ’s: OVERVIEW AND KEY REQUIREMENTS – FUNDAMENTAL #1 Purpose - The purpose of the laws and the regulations is to: Provide subsidized insurance to flood-prone areas; Require local jurisdictions to enact land use and flood control measures; Require flood insurance for loans secured by a building or a mobile home located in a special flood hazard area in a participating community; and Provide notice of the risk of flooding and the availability of subsidized flood insurance to owners of buildings and mobile home located in special flood hazard areas. NOTE: This is not a typical “consumer” compliance protection law. The purpose of the law is to protect the GOVERNMENT’S program for flood insurance for residential AND commercial property. Lenders have been “deputized” to enforce the provisions. IT IS COLLATERAL DRIVEN – NOT PURPOSE DRIVEN!! COVERAGE OF REGULATIONS General Rule The regulations apply when (MIRE) making, increasing, renewing or extending a loan: Secured by a building or a mobile home Located or to be located in an area determined by the Director of the Federal Emergency Management Agency to have special flood hazards.
Floodhoab081915.docx