Exams Show CUs Not Complying with Flood Insurance Requirements
ALEXANDRIA, Va.-In a recent review of examination findings, NCUA found that "some credit unions are not fully complying with the requirements of Part 706" (requirements of the National Flood Insurance Program). Letter to Credit Unions 04-CU-16 provides a reminder of the key provisions of the program, including: * a credit union cannot make, increase, renew or extend a loan secured by personal property located in a special flood hazard area unless it is covered by flood insurance for the term of the loan, with few exceptions; * credit unions may charge a reasonable fee for determining whether the property is in a flood area; * the credit union must notify the borrower within a reasonable timeframe, typically 10 days, if the property is located in a flood area; * if flood insurance is available in the flood area, the credit union must require the borrower to buy insurance sufficient to cover the principal of maximum limit of coverage under the flood act; * the flood insurance must be escrowed with taxes, insurance premiums, etc. if the credit union requires they be escrowed; * credit unions must notify the Federal Emergency Management Agency of the loan services when the loan is made, increased, extended, renewed, sold or transferred; and * if the credit union finds the flood insurance coverage has lapsed, the credit union must notify the borrower that it must be purchased. If no proof of insurance is provided in 45 days, the credit union is required to purchase it on the borrowers' behalf and charge the cost of premiums and fees. NCUA is authorized to assess fines for failure to comply, the letter reminds.