By Michael R. Christians
Following the onslaught of activity generated by the Consumer Financial Protection Bureau’s (CFPB) new mortgage rules which took effect this past January, many credit unions—after taking all of twelve seconds to sit back and relax—find themselves wondering what the “next big thing” is in the area of mortgage lending compliance. Those of you who were anxious to establish mandatory escrow accounts for flood insurance in all of your newfound free time, might want to stop reading now.
In July 2012, Congress passed the Biggert-Waters Flood Insurance Reform Act. This legislation was designed to overhaul the Flood Disaster Protection Act of 1973 and place the National Flood Insurance Program (NFIP) on firmer footing. Some provisions of Biggert-Waters were effective upon enactment while others are awaiting the publication of final implementing regulations. On October 30, 2013, the National Credit Union Administration (NCUA) alongside other federal regulators published their joint proposed rule to implement the Act; however, as of publication, no final rule has yet been announced.