VIEWpoint Issue 1 | 2022
Brief Insights | Meeting Provider Relief Fund Reporting Requireme...
VIEWpoint Issue 2 | 2021
2022 Q4 Tax Calendar: Key Deadlines for Businesses and Other Empl...
Ask the Advisor: Key Tax Incentive Changes
Weathering the Storm of Rising Inflation
On Jan. 21, 2020 the Office of the Comptroller of the Currency (OCC) announced a $17,998,510 civil money penalty (CMP) against Citibank for flood requirement violations. The Flood Disaster Protection Act (FDPA) and its implementing regulations apply to financial institutions including Citibank that make, increase, extend and renew loans secured by buildings or mobile homes (“Collateral”) located in a special flood hazard area in which flood insurance is available under the FDPA (“Designated Loans”). The FDPA also requires covered financial institutions to have a compliance program to monitor its Designated Loans.
Citibank’s compliance program to monitor its Designated Loans was intended to ensure that the collateral securing the Designated Loans was appropriately covered by flood insurance. Citibank used a third-party to service Designated Loans within its residential lending units to notify the borrowers and force place flood insurance when the flood insurance failed to appropriately cover the collateral. The OCC determined in 2017, that since 2014, Citibank’s policies and procedures allowed its third-party servicer to extend the 45-day period after notification to the borrower, resulting in the untimely force placement of flood insurance on Designated Loans.
This publication is distributed for informational purposes only, with the understanding that Doeren Mayhew is not rendering legal, accounting, or other professional opinions on specific facts for matters, and, accordingly, assumes no liability whatsoever in connection with its use. Should the reader have any questions regarding any of the news articles, it is recommended that a Doeren Mayhew representative be contacted.
A quick registration is required to view our resources.
You will only be asked to do this one time (unless you don't save your browser cookies).