Flood Insurance Proposal

Ever since the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) was passed we have been anxiously awaiting the promised regulatory guidance to help us implement it. Specifically, we want more information concerning the exemption for detached structures on residential property.

Unfortunately, the proposal issued on October 24, 2014, offers no definition of “residential property”.  The proposal indicates, “Flood insurance is not required for any structure that is part of any residential property but is detached from the primary residential structure of such property and does not serve as a residence”. That’s exactly what the HFIAA already said!   Instead, the Agencies are requesting comments on whether to or how to define “residential property”.  Whether to?  Absolutely, they need to define it so everyone is playing the same game.  I understand this for a lot in town with a house and detached structures would be residential property, but what about a farmyard with a house, barn, grain bins, etc.? Does that qualify? We NEED more answers!

It looks like the ball is in our court, which means we can submit comments and recommend our own definition of a “residence”. Please refer to the Federal Register (in the “Addresses” section) for your regulator’s submission instructions.  All comments  must be submitted on or before December 29, 2014.  Looks like we just have to sit back and wait for clarification…AGAIN!

For more information on this and other issues addressed in the proposal, please see our November Newsletter (available November 1st).

Stay tuned!

Published
2014/10/13
David Dickinson
David Dickinson

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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