Regulations surrounding flood are continually evolving and can be daunting. At OSC we have a deep understanding of the complexity and importance of keeping up with changes in policies and implementing best practices. Kirk Stephens, Chief Compliance Officer, regularly presents on the topic of flood risk management and our entire operations and technology team is well-versed in its proper application.
With changes in NFIP and private flood coverage availability, flood zone determinations and significant cost considerations for lenders and servicers of residential and commercial interests, we are committed to delivering actionable insights on all things flood. This includes regular regulatory bulletins, training forums and sharing knowledge gained from frequent review and participation in government and industry association activities. Some of the flood services we offer include waterfall calculations for proper coverage confirmation, flood determinations, integrated insurance and tracking solutions, consumer-friendly flood communications, and private flood policy portfolio assessments.
Private Flood Policy Assessment
With the Biggert-Waters Flood Insurance Reform Act of 2012, private flood insurance is accepted if it equates to the National Flood Insurance Policy coverage standards. However, this acceptance requires lenders to evaluate these policies for compliance with the statutory definition of “private flood insurance” and to ensure they meet minimum requirements. It’s no picnic as get it wrong, and regulators can criticize you for accepting non-compliant policies. This burden for many is great as resources may be understandably limited.
At OSC, we help clients understand and apply the evolving private flood policy rules to their portfolios to mitigate risk. Our experienced compliance officer and team actively monitor a range of regulatory sources—including the FHA, OCC, FDIC, CFPB, FNMA, FHLMC, NFIP, and GNMA—to provide sound guidance on your private flood policies. We are equipped to handle your policy audit and deliver actionable insights to your team in a timely manner.
We will work closely with your loan operations and/or compliance team to:
- Access each private flood policy in a secure, electronic manner
- Generate a tracking ticket to process the policies efficiently
- Review policies against all key private flood guidelines
- Provide an actionable assessment of the policy against regulatory requirements and provide recommendations
Assessment criteria included but not limited to:
- Assessment against the statutory definition of “Private Flood Insurance”
- Discretional acceptance criteria outlined in the Agencies’ Final Rules
- Licensure of the insurance carrier
- Breadth of coverage
- Cancellation/non-renewal notice requirements
- Strength of the mortgage interest clause
- Legal recourse
- Safety and soundness elements