Civil Money Penalty Waves

Please, please, please make sure your bank is dotting i’s and crossing t’s when it comes to flood insurance Jerod11requirements/compliance.  Increased maximum civil money penalties for non-compliance with flood insurance requirements are on the way.  As directed by the Biggert Waters Flood Insurance Reform Act of 2012, both the Federal Reserve Board (FRB) and Office of the Comptroller of the Currency (OCC) have publically declared their right to invoke the maximum civil money penalties as applicable.  The penalty is increasing from $385 to $2,000 per violation and the annual cap has been eliminated.  You can read all about it at the links provided below.  Oh, and don’t worry, if you’re not regulated by the FRB or OCC the other agencies will be sure to follow!

FRB:  http://www.gpo.gov/fdsys/pkg/FR-2012-11-16/pdf/2012-27857.pdf

OCC:  http://www.gpo.gov/fdsys/pkg/FR-2012-11-06/pdf/2012-27074.pdf

Jerod Moyer

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