TOPIC: Community Bank

Flood Insurance checklist and general procedure for review of Private and NFIP/FEMA Policies

VP at a bank ($903MUSA)
Thank you to the ladies of Sterling Compliance  for giving us a head start on a checklist for use with private flood Insurance.  With their permission, I'm posting my additions/revisions to match the way I've now learned how to attack this process.  For state requirements, I am in CA, so you'll need to update this part.   Here is the general process:
  • Section A -per the FEMA Insurance Agent's manual, things required on all new and renewed flood policies & universal needs,, then IF PRIVATE:
  • Section B - Mandatory acceptance of a Private Policy if it meets Section A and has the Compliance Aid Statement, OR
  • Section C - Mandatory acceptance req of a Private policy if meets Section A and the regulatory requirements (I call Manual method)  OR
  • Section D - Discretionary acceptance - criteria I came up with for my bank, as we are likely to accept if it has the minimum NFIP amounts as issued by a private  insurer (and Section A requirements too).  I need one last check with my CCO to ensure he is on board this will be S&S enough for the bank, but confident so at this juncture.
  • End - If we can't even get this to match, then we would have policy reviewed by Credit Admin for a determination that meets S&S standards. Might make this into a step E to clarify it is post Section D that this would needed. 
We have very few flood loans and even fewer private policies, but I am having all of them reviewed with this process in advance of the 7/1/19 date so we get a feel for how it works as we complete implementation.    If you use and upgrade - please share and let me know!