Flood Insurance Coverage Documentation

The longer you’ve been in compliance, the more you understand that nothing seems to stay the same.  Between new regulations and new interpretations of old regulations, change is inevitable.

We experienced this recently when our Team was discussing flood insurance coverage documentation.  We often get the question of whether a bank should keep copies of all policies for the life of the loan (to prove continuous coverage) or should they keep only evidence of coverage at closing and the current policy?  We had been in the camp of the latter (see our 1/21/08 blog); however we have changed our tune.

We now believe it is prudent to keep evidence of flood insurance coverage from the date of loan closing for the entire life of the loan.  This is not necessarily based on a change in the regulatory requirements or the now rescinded FEMA Guidelines but the Biggert-Waters Flood Act, does impose much stiffer violations for flood compliance.  If you can save a few extra pieces of paper and eliminate civil money penalties, we think it’s worth it.


David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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