NFIP Reauthorization and OCC Bulletin Update
The National Flood Insurance Program (NFIP) will expire on September 30, 2021. The NFIP Extension Act of 2021 is under consideration in the U.S. Senate. If passed by Congress and signed by President Biden, the Act would extend the NFIP program to December 3, 2021.
In the event that the reauthorization is not issued by 11:59 p.m. on September 30th, Proctor Loan Protector would like to draw attention to guidance previously issued by agencies that address lapses in FEMA’s authority under the NFIP. This guidance provides answers to frequently asked questions, entities’ responsibilities and a sample letter of reference. For complete details, please review the bulletins below:
- FEMA: W-17069, Guidance on Potential Lapse in NFIP Authority
- OCC: Guidance Regarding Lapse and Extension of FEMA’s Authority to Issue Flood Insurance Contracts
- FDIC: Lapse of FEMA Authority to Issue Flood Insurance Policies
An expiration of the NFIP program would not affect your lender-placed flood insurance program with Proctor Loan Protector. Proctor Loan Protector will continue to monitor this topic and provide updates as they develop.
OCC BULLETIN UPDATE
The OCC published Bulletin 2021-44 to alert regulated entities about two new handbooks which were issued to replace previous examination guidance booklets. The “Earnings” booklet updates procedures for reviewing earnings for specific lines of business, provide information on conducting earnings analysis, and discusses risk management principles such as budgeting and forecasting. The “Regulatory Reporting” booklet provides information for examiners on common reports, assists with determining the materiality of a misstatement in a regulatory report, and updates procedures for assessing banks’ reporting activities.
The “Earnings” and “Regulatory Reporting” booklets do not directly impact Proctor Loan Protector. Proctor Loan Protector will continue to monitor and provide information on regulatory updates.