OCC Bulletin 2009-26| August 6, 2009

Flood Disaster Protection Act: Revised Interagency Questions and Answers Regarding Flood Insurance


Chief Executive Officers and Compliance Officers of All National Banks, Department and Division Heads, All Examining Personnel, and Other Interested Parties

The guidance attached to this bulletin continues to apply to federal savings associations.

On July 21, 2009, the Office of the Comptroller of the Currency, along with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, Office of Thrift Supervision, National Credit Union Administration, and the Farm Credit Administration (the agencies), published in the Federal Register "Interagency Questions and Answers Regarding Flood Insurance" (2009 Interagency Questions and Answers).

This document supersedes the 1997 Interagency Questions and Answers and supplements other guidance or interpretations issued by the agencies and the Federal Emergency Management Agency (FEMA). The 2009 Interagency Questions and Answers include 77 questions and answers, that were revised as appropriate based on comments from 59 commenters.

The agencies also are proposing five additional questions and answers. The new proposed questions and answers provide guidance concerning the determination of insurable value in calculating the maximum limit of coverage available for the particular type of property under the Flood Disaster Protection Act and force placement of required flood insurance. The agencies invite comment on the proposed new questions and answers and, more generally, on other issues and concerns regarding compliance with the federal flood insurance statutes and regulations. Comments specific to determination of insurable value and force placement of required flood insurance are requested by September 21, 2009.

You may direct any questions to your supervisory office or OCC Compliance Division (202) 649-5470.

Ann F. Jaedicke
Deputy Comptroller for Compliance Policy

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