Flood FAQs...Finally!
By David Dickinson
It's a good thing we didn't hold our breath. Back in July 2009, the regulatory agencies issued FAQs to the Flood Insurance requirements which also included 5 additional proposed FAQs. Well . . . they . . . finally . . . got . . . around . . . to (OK, you get my joke) - they finally got around to finalizing some (but not all) of the proposed FAQs. Technically, they haven't officially been published in the Federal Register, but the regulatory agencies gave us a preview with this announcement.
Unfortunately, it takes the agencies 38 pages to make this announcement. Let me give you the cliff notes:
The Agencies are adopting two of the five questions and answers proposed in the 2009 Interagency Questions and Answers: one question and answer relating to insurable value (question and answer 9) and another question and answer relating to force placement of flood insurance (question and answer 61). The Agencies are also withdrawing one question and answer relating to insurable value . . . . (question and answer 10). However, as discussed below, because the Agencies propose to significantly and substantively change the answers to two of the questions and answers relating to the force placement of flood insurance, the Agencies are proposing them for additional comment (questions and answers 60 and 62). In addition, the Agencies are proposing changes to a previously finalized question and answer (question and answer 57) that also relates to the force placement of flood insurance to be consistent with the proposed changes to these two questions and answers.
We'll be analyzing this new guidance and telling you more about what it has to say in our November e-newsletter. Here's a link to the 2009 FAQs so you can research more on your own, if you have the urge.
I wonder how long it will be before we get the final-final FAQs?