On August 22, 2019, the Federal Reserve announced the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council updated the Interagency Consumer Examination Procedures for the Flood Disaster Protection Act (FDPA). The Biggert-Water Flood Insurance Reform Act of 2012 changed the flood insurance rules for private flood insurance. There is now mandatory acceptance of a private insurance policy to satisfy the flood insurance purchase requirements if the policy meets the statutory and regulatory definition of private flood insurance. In addition, even if the policy does not meet the statutory and regulatory definition of private flood insurance, there can be a discretionary acceptance of a flood insurance policy issued by a private insurer. Finally, if certain criteria are met, there can be discretionary acceptance of a plan issued by a mutual aid society satisfying the flood insurance purchase requirement.



John Zasada, JD, CAMS – Compliance Consulting Director, Financial Institutions Group. John can be reached at zasada@doeren.com.