Contact Us FDIC CONSUMER COMPLIANCE EXAMINATION MANUAL UPDATES
The FDIC published a November 2026 update to its Consumer Compliance Examination Manual (CEM), revising Chapter V-6, Flood Disaster Protection Act.The update removes FDIC-specific instructions on mutual aid society plans, including the qualification of such plans. Going forward, FDIC examiners will evaluate whether mutual aid society plans qualify as flood insurance on a case-by-case basis, consistent with the criteria set forth in 12 CFR 339.3(c)(4).
The regulatory criteria for accepting a mutual aid society plan are unchanged. A regulated lending institution may, at its discretion, accept such a plan if the institution’s primary federal supervisory agency has determined that such plans qualify as flood insurance; the plan provides coverage in the amount required; the plan covers both the mortgagor(s) and mortgagee(s) as loss payees; and the plan provides sufficient protection of the designated loan, with the institution documenting its conclusion in writing.
We encourage all clients to review the updated chapter and the FDIC’s redline in their entirety for additional information.