Flood Insurance Proposal

Ever since the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) was passed we have been BSA Training and Banking Regulations Compliance Consulting dave11 - Flood Insurance Proposalanxiously awaiting the promised regulatory guidance to help us implement it. Specifically, we want more information concerning the exemption for detached structures on residential property.

Unfortunately, the proposal issued on October 24, 2014, offers no definition of “residential property”.  The proposal indicates, “Flood insurance is not required for any structure that is part of any residential property but is detached from the primary residential structure of such property and does not serve as a residence”. That’s exactly what the HFIAA already said!   Instead, the Agencies are requesting comments on whether to or how to define “residential property”.  Whether to?  Absolutely, they need to define it so everyone is playing the same game.  I understand this for a lot in town with a house and detached structures would be residential property, but what about a farmyard with a house, barn, grain bins, etc.? Does that qualify? We NEED more answers!

It looks like the ball is in our court, which means we can submit comments and recommend our own definition of a “residence”. Please refer to the Federal Register (in the “Addresses” section) for your regulator’s submission instructions.  All comments  must be submitted on or before December 29, 2014.  Looks like we just have to sit back and wait for clarification…AGAIN!

For more information on this and other issues addressed in the proposal, please see our November Newsletter (available November 1st).

Stay tuned!

Published
2014/10/13
David Dickinson

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