National Flood Insurance Program - H2O Partners, Inc

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D e m ys t i f y i n g t h e L e n d e r Q & A s

© FEMA 2009. All rights reserved © FEMA 2009. All rights reserved

Demystifying the Lender Q&As

National Flood Insurance Program

© FEMA 2009. All rights reserved

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© FEMA 2009. All rights reserved © FEMA 2009. All rights reserved

Welcome to Demystifying the Interagency Q&A!

We will get started in a few minutes. Meanwhile, let’s perform a warm up exercise.

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1. Federal Register- Interagency Q & As Regarding Flood Insurance (July 2009)

http://edocket.access.gpo.gov/2009/pdf/E9-17129.pdf

2. Federal Register- Interagency Q & As Regarding Flood Insurance (October 2011)

http://www.gpo.gov/fdsys/pkg/FR-2011-10-17/pdf/2011-26749.pdf

3. Interagency Statement on the Impact of Biggert-Waters Act (March 2013)

http://www.fdic.gov/news/news/financial/2013/fil13014.pdf

4. Joint Notice of Proposed Rulemaking on Loans in Areas Having Special Flood Hazards (October 2013)

http://www.fdic.gov/news/board/2013/2013-10-08_notice_dis_a_fr.pdf

Seminar Resources

Q.1 3



•Designated Loans

•Amount of Flood Insurance Required

•Flood Insurance Requirements for:

Construction Loans

Non-residential Buildings

Residential Condominiums

Home Equities/Seconds

Sale/Transfer Notices

Seminar Agenda

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•Escrows

•Force Placement

•Private Flood Insurance

•Required Use of SFHDF

•Flood Determination Fees

•Flood Zone Discrepancies

•Notices to Borrower

•Mandatory CMPs

Seminar Agenda

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I. Determining When Certain Loans are Designated

Demystifying the Q & As

(Questions 1-7)

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Designated Loan: What is a ‘designated loan’?

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• A loan secured by a building or mobile home that is located or to be located in a “special flood hazard area” in which flood insurance is available under the Act.

Please note: Emphasis on a “building or mobile home” as collateral.

Q.1



•Loan purchase is not a tripwire

•No automatic requirement to make a new flood determination or require a borrower to purchase flood insurance

•However, if a lender becomes aware that flood insurance is required, lender must comply with the rules, including force placement, if necessary.

•Tripwires are…

Does loan purchase trigger any requirements under the regulation?

8 Q.3

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M-I-R-E

Mandatory Purchase Tripwires

9

• Making

• Increasing

• Renewing

• Extending



Loan Syndication/Participation

10

• Acquisition of an interest in a loan via participation or syndication post-origination is not a mandatory purchase trigger.

• But a group of lenders that are Making, Increasing, Renewing or Extending a loan by pooling or contributing funds are subject to mandatory purchase requirements.

• Each participating lender is responsible for ensuring compliance – even when a lead lender is designated to handle compliance duties.

Q.4

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• Restructured or modified loans that are “designated loans”…

• Are subject to mandatory purchase regulations if…

• Lender increases the amount of loan, or

• Extends or renews term of original loan.

Restructured/Modified Loans

11 Q.5



II. Determining the Appropriate Amount of Flood Insurance

III. Exemptions from Mandatory Purchase


(Questions 8-18)

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Amount of Flood Insurance

13

• Amount of Flood Insurance = lesser of:

• Outstanding principal balance of loan(s)

• Maximum amount of insurance available under the NFIP, which is the lesser of:

The maximum limit available for the type of structure; or

The insurable value of the structure

Q.8



NFIP Coverage Limits

Emergency Program Regular Program

Single Family

Building $35,000 $250,000

Contents $10,000 $100,000

Other Residential

Building $100,000 $250,000

Non-Residential

Building $100,000 $500,000

Contents $100,000 $500,000

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Residential Buildings

15

• 1 – 4 family dwellings

• Apartments with > than 4 units

• Condominiums & cooperatives in which at least 75% of square footage is residential

• Hotels or motels where normal occupancy is 6 months or >

• Rooming houses with more than 4 roomers

• Residential buildings permitted incidental non-residential occupancies of less than 25%; 50% for single-family dwellings

Q.11



• Small businesses, Churches,

• Schools, Farm buildings (including grain bins and silos),

• Pool house, clubhouses, recreational, mercantile buildings,

• Industrial structures, warehouses, nursing homes,

• Hotels (rental < 6 months)

• Mixed–use buildings with less than 75% residential square footage

Non-residential Buildings

16

Q.12

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• Lender makes a loan in the principal amount of $150,000 secured by five nonresidential buildings, only 3 of which are located in SFHAs

Lender Case Study: Coverage for Multiple Buildings

Outstanding Loan Balance

• $150,000

Maximum amount of insurance under NFIP,

lesser of

• Maximum limit available: $500,000

• Insurable Value: $100,000 per building (Total $300,000)

Amount Required

Q.14

?



• Lender makes a loan in the principal amount of $150,000 secured by five nonresidential buildings, only 3 of which are located in SFHAs

Lender Case Study: Coverage for Multiple Buildings


• $150,000

Maximum amount of insurance under NFIP,

lesser of

• Maximum limit available: $500,000

• Insurable Value: $100,000 per building (Total $300,000)

Amount Required

• $150,000 (allocated amongst all 3 buildings)

Q.14

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What is the “insurable value” of a building?

• RCV for certain residential and condo buildings

• RCV for non-residential buildings may not be practical

• Avoid creating situations where borrower is “over-insured”

• Functional/Demolition values

• Consider loss settlement provisions of NFIP policy

• Careful not to “under-insure”

Final Question and Answer #9

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RCV vs. ACV

Replacement Cost Value

Cost to repair or replace a building

Material of similar kind and quality

No deduction for depreciation

RCV does not include land values

RCV is not “market value”


20 Q.9* *Final

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RCV vs. ACV

Actual Cash Value

Cost to replace an insured item of property at time of loss

Less the value of its physical depreciation

Based on age, wear and tear

Replacement cost less depreciation


21 Q.9* *Final



Final Answer

Insurable value approaches/methods

Appraisal based on cost-value approach

Construction-cost calculation

Insurable value used in hazard policy

Any other reasonable approach that can be supported


22 Q.9* *Final

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Final Answer – Wrap-up

Note from preamble:

“It is important for lenders to recognize that insurable value is only relevant to the extent that it is lower than either the outstanding principal balance of the loan or the maximum amount of insurance available from the NFIP.”


23 Q.9* *Final



Are there alternative approaches to determining the insurable value of a building?

See alternatives suggested in Q. 9

Agencies withdraw question as no longer necessary

Proposed Question and Answer #10

24 Q.10*

*Withdrawn

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Insurable Value Alternatives

Functional Building Cost Value

Demolition/Removal Cost Value



Dairy barn functions as storage building…

…Replaced by storage building

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Demolition/Removal Cost Value



Key points to remember:

• An NFIP policy will not cover an amount exceeding a building’s insurable value.

• Lenders are permitted to require more flood insurance coverage than the minimum required.

• A lender may not allow a borrower to use a high deductible to avoid mandatory purchase.

• Exemptions:

State-owned properties

Original loan balance $5K or less and term one year or less


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Flood Insurance Purchase Requirements

IV. Constructions Loans

V. Non-Residential Buildings


(Questions 19-25)

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• Compliance options:

• Require purchase of policy at time development loan is made.

• Require flood insurance at time of specified drawdown of loan for actual construction.

Monitor for actual start of construction.

No 30-day waiting period with either option.

• Buildings eligible for coverage prior to walled and roofed

• Materials and supplies eligible for coverage

• Rates based on construction drawings

Construction Loans

30 Q.22

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•Lenders are required to mandate flood insurance for buildings with limited utility or value if they comprise a “designated loan”.

•Lenders may consider “carving out” such buildings from the security it takes for loan.

•Be careful to analyze all risks of this option, e.g. ability to market property in event of foreclosure.

Non-Residential Buildings

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Q.24



Flood Insurance

Purchase Requirements

VI. Residential Condominiums


(Questions 26-33)

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Lender Case Study

• You take a residential condominium unit located in a 5 story condo building as collateral for a loan.

• Unit is on 4th floor

• Building is within a SFHA

Since you feel it highly unlikely that the units on the fourth floor would ever be flooded, what, if anything must you do with regard to the mandatory purchase

requirements?

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… (continued) But I Live On The Fourth Floor

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Condos and Coverage Forms



Residential Condominium Building Association Policy

RCBAP

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• Insures a residential condominium building owned by a condominium association.

• If insured to at least 80% of its replacement cost value at the time of loss or max limit there is no coinsurance penalty.

• RCBAP automatically provides Replacement Cost (RC) loss settlement for the building elements.

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Maximum Amount of Insurance

RCBAP

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• The maximum available building coverage is the replacement cost value of the building and its supporting structure or up to $250,000 per unit times the number of units, whichever is less.



Residential Condominium Building Association Policy

RCBAP

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• Insures a residential condominium building owned by a condominium association.

• If insured to at least 80% of its replacement cost value at the time of loss or max limit there is no coinsurance penalty.

• RCBAP automatically provides Replacement Cost (RC) loss settlement for the building elements.

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Revisions to RCBAP Documentation as of 10/1/07

• Number of units in structure • Statement of Replacement Cost

RCBAP

39

• •

Other Residential Townhouse/Rowhouse No Basement 8 Units Replacement Cost:$939,000 Coverage Amount: $800,000

$800.000

$939,000



Revisions to RCBAP Documentation – as of 10/1/10

• Agent must update RCV • information at least every 3

years

• RCV notification letter from carrier

RCBAP

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•

“The letter is to inform you that the Replacement Cost Value (RCV) on file for the building referenced above, insured under the Residential Condominium Building Association Policy (RCBAP), must now be updated. The National Flood Insurance Program (NFIP) requires that the RCV be evaluated every 3 years; it has been at least 3 years since the RCV for the building has been updated.”

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Covers the Residential Unit Owner

Dwelling Policy Form

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• Insures a single family dwelling unit in a condominium building or a non-condominium 1-4 family dwelling.

• A condominium unit in a townhouse, rowhouse, high-rise or low-rise building is considered to be a single family dwelling.

• Maximum limits - $250,000 building & $100,000 contents.



Covers Other Residential Condo Associations

General Property Form

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• Occupied less than 75% residential and not eligible for RCBAP.

• Maximum limit of $500,000 per building.

• The General Property Form provides Actual Cash Value coverage that includes a deduction for depreciation and Replacement Cost coverage is not available.

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Policy performance issue… …NOT compliance tool!

RCBAP Co-insurance penalty

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Compliant Loan Co-Insurance Penalty

• $1 million RCV

• $600K Cov. Limit (60%)

• 10 units

• Avg. Cov./unit = $60K

• Loan Amt. = $50K

Policy Performance vs. Compliance

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Non-Compliant Loan No Co-Insurance Penalty

• $1 million RCV

• $800K Cov. Limit (80%)

• 10 units

• Avg. Cov./unit = $80K

• Loan Amt. = $90K

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Amount of insurance at time of loss Amount of insurance required

X Amount of Loss

(Before Deductible)

= Limit of Recovery

Applies To The Building Coverage Limit Applies to Building Coverage Limit RCBAP Co-Insurance Penalty



$600, 000 Coverage Limit $1 million X .80 = $800,000

X $250,000 loss

(Before Deductible)

= $187,500 (less deductible)

Applies To The Building Coverage Limit

=75.0%

Applies to Building Coverage Limit

RCBAP Co-Insurance Penalty

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Dwelling Policy

• Pays assessments resulting from “direct physical loss by or from flood” to building common elements.

• Loss assessment coverage responds if:

• No RCBAP

• RCBAP insured to at least 80% of RCV

• If not insured to at least 80%:

Available for loss assessments to cover building damage in excess of 80% required amount.

Will not pay co-insurance penalty/association’s deductible.

• Unit owner coverage is excess over RCBAP – see “Other Insurance” clause.

Unit Owner Coverage

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Flood Insurance Purchase Requirements

VII. Home Equities, Lines of Credit, Subordinate Liens and Other Security Interests

VIII. Event of Sale/Transfer of Designated Loans


(Questions 34-50)

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No significant changes…

Home equities, second mortgages and other junior liens are subject to mandatory purchase requirements for flood insurance

Determinations are required if there is a triggering event (make, increase, extend or renew)


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• Must obtain least of:

loan amount (including the 1st mortgage)

maximum available under the NFIP

the insurable value of the building

• Should ensure that borrower adds junior lien holder's name as mortgagee/loss payee to existing policy

• Lender has option to pull credit report to obtain balance of 1st mortgage


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• Lender A makes a first mortgage with a principal balance of $100,000, but improperly requires only $75,000

• Lender B makes a $50,000 equity loan

• Lender B must ensure that policy increased to $150,000, not to only require increase of $50,000

Home Equities/Second Mortgage

COMBINED


• $100,000 + $50,000 = $150,000

Maximum amount of insurance under NFIP, lesser of

• Maximum limit $250,000

• Insurable Value $200,000

Q.36



•Questions 38 – 41 ; Summary of Key Points

A loan that finances inventory in a building in a SFHA where the building is not security for the loan is NOT a “designated loan”.

A loan secured by both building and contents when building is in a SFHA requires flood insurance on both the building and its contents.

If loan is secured by a building in a SFHA and by contents in another building, flood insurance is not required on the contents.

The regulation applies even in circumstances involving “abundance of caution”.

Other Security Interests

52 Q.38-43

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No significant changes…

• Notice of Servicer’s Identity:

• Lenders must notify the insurance provider/carrier in writing of the identity of the servicer of the loan and any change in servicer.

• Notice of change of servicer must be done within 60 days of change effective date.

Change notices may be sent directly to the insurance provider by the mortgagee.

• In the event of merger/acquisition, duty to provide notice falls to successor institution if not provided by the acquired institution

prior to effective date of merger/acquisition.

Event of Sale/Transfer of Loans

53 Q.36-43



IX. Escrow Requirements

X. Force Placement

XI. Private Flood Insurance


(Questions 51-64)

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•Lenders are required to escrow flood insurance premium and fees for mandatory flood insurance if the lender requires the escrow of taxes, hazard insurance premiums or any other charges for “residential improved real estate”

•Exception: Voluntary Escrow

Escrow Requirements

55 Q.52-53

The 2012 Reform Act contains a provision on escrows that is due for implementation effective July 6, 2014. It

will be implemented through notice and comment rulemaking. Regulators intend to publish escrow

regulations in time to implement prior to July 2014*

Interagency Statement of the Impact of Biggert-Waters Act – March 29, 2013



Joint Notice of Proposed Rulemaking

Which loans affected?

• Required for loans secured by “residential improved” real estate of mobile homes

• Outstanding or entered into on or after 7/6/2014

When do escrows begin?

• Phased in beginning 7/6/2014:

Outstanding loans

New loans

Become designated loans, e.g. map changes

Proposed Escrow Requirements

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Notice to borrowers?

• New loans

• Outstanding loans

• Loans that become designated loans, e.g. map changes

• Any Exceptions?

• Total assets < $1 billion

• Escrows not previously required under Federal/State law*

• No policy of requiring escrows*

*Loans secured by residential improved real estate or a mobile home







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What is the requirement for the force placement of flood insurance under the Act and Regulation?

With revisions to proposed Q&As 60 and 62, the agencies are proposing

revisions to previously finalized Q&A

Revised Proposed Question and Answer #57

57 Q.57*

*Proposed



Proposed Answer

Lenders are required to force place if all the following occur:

Lender determines collateral is in SFHA

Flood insurance is available under the Act

Lender determines coverage is inadequate or non-existent

After required notice, borrower fails to purchase appropriate amount


58

Force-Place

Allow time for borrower to purchase flood insurance

Send 45-day letter

Q.57* *Proposed

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Proposed Answer

Notice to borrower must state:

Borrower should obtain required amount at borrower’s expense

If not obtained within 45 days…

Lender will purchase on behalf of borrower

May charge borrower for cost of premium and fees

Which are likely more expensive than if borrower purchased


59 Q.57*

*Proposed



Proposed Answer

Agencies “best practices” encourage lenders to:

Advise borrowers of high cost of force place flood insurance

Send borrowers “Notice of Special Flood Hazards “

When borrower not previously required to buy flood insurance, e.g. map change


60 Q.57*

*Proposed

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When should a lender send the force placement notice to the borrower?

Issue Original proposed question addressed a lenders ability to accelerate notice

Revised Q&A focuses on the proper time to send notice


61 Q.60*

*Proposed



Proposed Answer

To ensure adequate flood insurance coverage is maintained, lender must:

Send force placement notice upon determining:

Coverage is inadequate

Coverage is expired

Notice is required when lender learns: Collateral placed in SFHA due to map change

Agencies recommend lenders advise borrowers flood coverage is expiring


62 Q.60*

*Proposed

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When must the lender have flood insurance in place if the borrower has not obtained adequate insurance within the 45-day notice period?

Declined to set an arbitrary number of days as requested

Lenders should have procedures in place to allow force placement to begin after 45-day notice expires


63 Q.61* *Final



Final Answer

Adopted with minor clarifications

Lender or servicer shall force place upon expiration of 45-day notice period

Agencies expect lenders to provide reasonable explanation for any brief delays, e.g. batch processing


64 Q.61* *Final

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When may a lender or its servicer charge a borrower for the cost of insurance that covers collateral during the 45-day notice period?

Issue Original proposed question asked does a lender or servicer have the “authority” to charge for flood insurance during the notice period

Revised Q&A clarifies when a lender may charge borrower


65



Premium and fees a lender or servicer may charge include:

Premium or fees incurred for coverage

Beginning on the date flood insurance coverage lapsed or,

Did not provide sufficient coverage amount

Adopted 2012 Reform Act Force Placement Provisions

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Requires lender or servicer within 30 days of:

Receiving confirmation of borrower’s coverage

Terminate force-place insurance

Refund all force-placed premium and fees paid by borrower

During any overlap in coverage


67



Requires lender or servicer to:

Accept borrower’s existing policy declarations page as confirmation

Declarations page must include:

Existing policy number

Identity/Contact information for insurance company or agent


68

Agencies’ Position: Force placement provisions of the Act

became effective upon enactment Interagency Statement of the Impact of Biggert-Waters Act – March 29, 2013







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Lenders must accept private flood insurance if:

• Insurer meets state department of insurance requirements

• Surplus Lines insurer must be recognized by state department of insurance

• Must be as broad as the NFIP policy

• 45-Day Cancellation/Non-Renewal Notice

• Information about availability of flood coverage under NFIP

• Must contain similar NFIP mortgage interest clause

• Provision requiring insured to file suit within one year after claim denied

• Cancellation provisions as restrictive as SFIP under NFIP

Proposed Private Flood Insurance Requirements

69

2012 Reform Act provision to be implemented through notice and comment rulemaking. Not effective until regulations are issued.



Requires Notice to Borrower to include:

Flood insurance is available thru private

companies from the NFIP.

Available directly from the NFIP (via agent)

Flood insurance that provides the same level of coverage as an NFIP policy may be available from private insurance companies.

Encourages borrowers to compare and contrast NFIP and private insurance policies.

Proposed Private Flood Insurance Requirements

70


2012 Reform Act provision to be implemented through notice and comment rulemaking. Not effective until regulations are issued.

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XII. Required use of SFHDF

XIII. Determination fees

XIV. Zone discrepancies

XV. Notice of flood hazards

XVI. Mandatory CMPs


(Questions 65-82)

71



Standard Flood Hazard Determination Form (SFHDF)

72

• New Form effective May 2012

• 3-Year Phase-in Period

• FEMA Form 086-0-32 replaces FEMA Form 81-93

• Not a substitute for the borrower notification form

• Providing copy to borrower is encouraged to reduce zone discrepancies

• Can also be used in event of other disputes like LODR

• Electronic form is acceptable

Q.65-67

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• May re-use when increasing, extending, renewing or purchasing a loan

• Cannot be reused when making a new loan

• Exceptions: Refinancing or assumption by same lender who obtained original determination and multiple loans to the same borrower only if:

It is less than 7 years old

No new or revised maps have been issued

Can the SFHDF be reused?

73 Q.68



Flood Determination Fees

74

• When determination is made in connection with M – I – R – E initiated by borrower.

• Prompted by a revision or updating by FEMA of flood zones.

• Prompted by FEMA’s publication of notices that affect the area where collateral is located..

• The determination results in force

placement.

Q.69-70

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What is a zone discrepancy?

Is the discrepancy between high-risk and low- or moderate-risk zone?

Lender should determine whether a result of the “Grandfather Rule”

Result of a mistake? Letter of determination review.

Flood Zone Discrepancies

75 Q.71



• 3 Types of zone discrepancies:

Grandfather rating rule


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Q.72

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• Allows a property owner to:

1. “Lock” in a previous flood zone

2. “Lock” in a previous Base Flood Elevation

Map Grandfather Rule

77





Too Close to Call


78

Q.72

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79





Too Close to Call

Purposeful manipulation


80

Q.72

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Too Close to Call


• Remedies

Document use of grandfather rule


81

Q.72





Too Close to Call


• Remedies


See Administrator’s April 2008 bulletin


82

Q.72

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83



84

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Too Close to Call


• Remedies


See Administrator’s April 2008 bulletin

Document file with actions taken

Resolve discrepancies to avoid possible violations


85

Q.72



•Developed to address the financial burden of mandatory purchase requirements on policy holders in newly mapped areas

•Buildings newly designated within the SFHA due to a map revision on or after October 1, 2008, are eligible for coverage under the PRP “until further notice”.

•Loss history requirements must be met

PRP Eligibility Extension Summary

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• Insurance Carrier, not lender, validates PRP extension eligibility

• Effective 10/1/2010, NFIP declarations pages will display two flood zones:

Current Flood Zone

Flood Risk/Rated Zone

• Current Flood Zone – flood zone of property on current (revised) Flood Insurance Rate Map (FIRM)

• Flood Risk/Rated Zone – flood zone from the previous map used to rate policy

• Lenders are not required to investigate or resolve differences between Current Flood Zone and Flood Risk/Rated Zone

PRP Eligibility Extension Summary (cont’d)



Rated Zone/Current Zone

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• If multiple borrowers, notice can provided to any one of the borrowers

•Records of receipt provided by the borrower must be maintained for the time that the lender owns the loan

Notice to Borrower

89 Q.73-78



•Unlike the re-use of the SFHDF, the lender must provide a new notice to the borrower, EVEN IF a new determination is not required.

•Neither the regulation nor the preamble addresses waiving the requirement to provide the notice to the borrower

Re-use of borrower notice?

90 Q.79

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•When a bank makes, increases, extends, or renews a loan secured by a building or mobile home located or to be located in a special flood hazard area…

•The bank shall mail or deliver a written notice to the borrower and servicer in all cases whether or not flood insurance is available under the Act for the collateral securing the loan.

•Notice to borrower cannot be re-used.

•Notice must be provided a “reasonable” time prior to closing.

Reasonable is generally regarded as 10 days

Notice to Borrower

91



Note from Interagency Q&A Preamble:

•What constitutes reasonable notice will necessarily vary according to the circumstances of particular transactions. Regulated lending institutions should bear in mind, however, that a borrower should receive notice timely enough to ensure that:

1. the borrower has the opportunity to become aware of his/her responsibilities under the NFIP

2. the borrower can purchase flood insurance before completion of the loan transaction.

Notice Requirements

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Original: Not to exceed $350 per violation, with a ceiling of $100,000 during a calendar year.

Biggert-Waters Reform Act increases CMPs to $2,000 per violation and eliminates the annual cap.

Looking for a “pattern or practice” of committing violations

Failure to:

• Place Insurance

• Escrow flood insurance premium

• Force place insurance

• Provide notice requirements

Mandatory civil money penalties

93 Q.81



We appreciate your participation in this webinar on the Interagency Q&A Update and look forward to your feedback.

Please take time to complete and help us improve our training effort!

THANK YOU!

Evaluations - Online

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Documents

National Flood Insurance Program - H2O Partners, Inc