Private Flood Insurance: Disparate Impact?

What do fair lending and disparate impact have to do with the new private flood insurance rules?

 

July 1, 2019, is the “go date” for the new private flood insurance requirements, which basically say that if a borrower provides the bank with a private flood insurance policy and it meets the definition of private flood insurance under the Rule, the bank is required to accept it.

 

Now it’s not quite that simple but you get the idea.

 

Since the Rule came out; however, there have been some evolutions. One of the things that keeps coming up is the issue of fair lending and disparate impact.

Within the Rule, there are two types of private policies where a bank is allowed to apply discretion with respect to whether or not they want to accept the private policy.

 

Listen to the video as Jerod explains more.

 

 

 

Since we are in the business of providing solutions, we’ve put together a last-minute webinar on the Private Flood Insurance Rules that will be held on May 29, 2019.  We’ll spend 30 minutes giving you the latest and greatest information we have.  We’ll look at the requirements and the evolution since the Final Rule was issued.  All this in time so you have time to adjust your program/procedures if necessary.

 

Register NOW!

 

Published
2019/05/21
Jerod Moyer

 

Want to find out more about Flood Insurance? See the regulation page here. https://www.bankerscompliance.com/banking-regulations-compliance-services/reviews-2/flood/

Jerod Moyer

Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!

Recent Posts

Specific Reasons When Taking Adverse Action

TRID: Closing Disclosure Accuracy

FinCEN Issues Financial Trend Analysis on Elder Exploitation