Banking Agency Issues Guidance on Flood Insurance

Disaster Response
Published

As NAHBNow previously reported, the Federal Emergency Management Agency (FEMA) extended the grace period for renewing flood insurance policies from 30 days to 120 days because of the COVID-19 pandemic. The extension of the grace period applies to policies expiring between Feb. 13, 2020, to June 15, 2020.

On April 15, 2020, the Office of the Comptroller of the Currency (OCC) issued a statement in response to the FEMA extension to provide guidance to the financial institutions it regulates, and address conflicts between the FEMA rule and banking agency flood insurance rules.

The guidance specifically addresses how financial institutions can address requirements under OCC’s flood insurance force placement regulations. When a bank determines that a designated loan is not covered by flood insurance or is not covered by a sufficient amount of flood insurance, it must notify the borrower that they should obtain sufficient flood insurance at the borrower’s expense for the remaining term of the loan. If the borrower does not provide evidence of sufficient coverage within 45 days after notification, the bank must force placement of flood insurance in an amount that will satisfy the regulatory requirements.

In recognition of the serious impact the COVID-19 emergency may have on consumers, OCC’s statement indicates that it will not take enforcement or supervisory action against banks for “reasonable delays in complying with” the OCC’s force placement of flood insurance regulations. OCC further states that banks could provide notification to borrowers 45 days prior to the end of the 120-day extended grace period concerning the need for sufficient coverage. Additionally, banks are reminded that if flood insurance is force placed during the extended grace period, the banks must refund the cost of the overlapping coverage to the borrower.

Without OCC’s clarification, the extension of the NFIP grace period could have resulted in a borrower being forced placed during the grace period when the borrower is fully covered by flood insurance. OCC is one of several financial regulating agencies, and additional guidance will be need from those agencies to fully address the issue.

For more information, contact Tamra Spielvogel at 800-368-5242 x8327.

Subscribe to NAHBNow

Log in or create account to subscribe to notifications of new posts.

Log in to subscribe

Latest from NAHBNow

Membership

Jul 21, 2025

NAHB Mourns Passing of Rick Herman

NAHB mourns the passing of Rick Herman, longtime Executive Officer of the Rochester Home Builders Association (RHBA) in New York. Rick joined RHBA 30 years ago and served as a tireless advocate for members in Rochester and around the state.

Construction Costs

Jul 18, 2025

Metals and Equipment Drove Material Prices Higher in June

Residential building material prices rose in June, driven primarily by higher construction machinery and equipment part prices, based on data from the most recent Producer Price Index (PPI). Metal commodities also experienced significant increases, following recently implemented tariffs on steel and aluminum.

View all

Latest Economic News

Economics

Jul 21, 2025

Use of Private Water and Sewer Systems in New Single-Family Homes

The share of new single-family homes built with individual septic systems declined slightly in 2024 compared to the previous year, while the share of homes served by private wells remained steady.

Economics

Jul 21, 2025

Sales of Lower-Priced New Single-Family Homes Declined Over the Past Five Years

From 2020 to 2024, sales of lower-priced new homes declined significantly as the market moved toward higher-priced segments. Rising construction costs—driven by inflation, supply chain disruptions, and labor shortages—as well as higher regulatory costs, made it increasingly difficult for builders to construct affordable homes.

Economics

Jul 18, 2025

State-Level Employment Situation: June 2025

Nonfarm payroll employment increased in 27 states in June compared to the previous month, while employment decreased in 23 states and the District of Columbia. According to the Bureau of Labor Statistics, nationwide total nonfarm payroll employment increased by 147,000 in June following a gain of 144,000 jobs in May.