CUNA Regulatory Comment Call


July 31, 2009

Agencies Finalize Revisions to Flood Insurance Q&As and Request Additional Comments

EXECUTIVE SUMMARY

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 or you may access them 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 revised the Q&As and are requesting comment on additional Q&As with regard to the calculation of insurable value and the forced placement of insurance when the property is no longer insured or underinsured.

DESCRIPTION OF THE CHANGES TO THE Q&As

Here are the significant changes to the Q&As that have now been finalized:

Here are the additional, proposed changes to the Q&As:

QUESTIONS TO CONSIDER REGARDING THE PROPOSED 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
Luke Martone • Senior Regulatory Counsel • (202) 508-6743 • lmartone@cuna.com