CUNA Regulatory Comment Call

April 8, 2008

Agencies Request Comment on Proposed Revisions to Flood Insurance Q&As

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.coop and to Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.coop; or mail them to Mary and Jeff c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may also contact us at 800-356-9655, ext. 6732, if you would like a copy of the Q&As. You may also access it here.

BACKGROUND

The National Flood Insurance Reform Act of 1994 (Act) comprehensively revised the flood insurance laws. NCUA and the other federal financial institution regulators issued a joint final rule in 1996 to implement the Act. These agencies then decided to issue additional guidance, resulting in the Q&As that were published in 1997. The agencies have now proposed revisions to the Q&As and are requesting comment before finalizing these changes.

DESCRIPTION OF THE CHANGES TO THE Q&As

Here are the significant changes to the Q&As that are being proposed:

QUESTIONS TO CONSIDER REGARDING THE FLOOD INSURANCE Q&As

Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Luke Martone • Senior Regulatory Counsel • (202) 508-6743 • lmartone@cuna.com