On March 29, 2013, regulators issued an interagency statement on portions of the Biggert-Waters Act. The bulletin clarifies a few of the amendments and (more importantly) when these provisions become effective.
The bulletin addresses:
- Force Placement (effective 7/6/12)
- Civil Money Penalties – $2,000 per violation with no cap (effective 7/6/12)
- Private Flood Insurance – acceptable standards and disclosures (not effective until regulations are issued).
- Escrows – clarification this only applies to residential real estate and the exemption for banks that are 1) < $1 billion AND 2) not required to and don’t require escrows (not effective until regulations are issued; however, the law requires this beginning 7/6/14).
- Clarification about 3 of the proposed FAQs pertaining to force placement. One will be dropped and the other two will be reviewed after new regulations are issued.
Apparently, the regulators will be issuing new regulations to adopt the Biggert-Waters Act changes. In the past, FEMA has been slow and issued few regulations regarding the Flood Insurance Act. However, it appears we may see much needed clarification soon – just don’t hold your breath!
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.