Synergy by Association
  • About Synergy
    • Contact Us
    • Board of Directors
    • Synergy Partner Advisory Committee
  • PROGRAM PARTNERS
    • ABA Insurance Services
    • Bank Marketing Center
    • Bankers Alliance
    • Cornerstone Advisors
    • CRA Partners
    • Discover Debit
    • Hagan Hamilton
    • ICBA Securities
    • KeyState Captive Management
    • ODP Business Solutions
    • ServisFirst
    • Shred-it
    • StrategyCorps
    • Vericast
  • ASSOCIATION ALLIANCES
  • PARTNER TOOLKIT
  • About Synergy
    • Contact Us
    • Board of Directors
    • Synergy Partner Advisory Committee
  • PROGRAM PARTNERS
    • ABA Insurance Services
    • Bank Marketing Center
    • Bankers Alliance
    • Cornerstone Advisors
    • CRA Partners
    • Discover Debit
    • Hagan Hamilton
    • ICBA Securities
    • KeyState Captive Management
    • ODP Business Solutions
    • ServisFirst
    • Shred-it
    • StrategyCorps
    • Vericast
  • ASSOCIATION ALLIANCES
  • PARTNER TOOLKIT

Compliance Alliance Question of the Week

5/8/2019

 
​Question:
We have a potential borrower who has several buildings we will be taking as collateral. The corner of one building is in a flood zone. We have requested flood insurance covering the entire building. Our borrower stated that his previous lender allowed them to obtain flood insurance on the one unit of the building that has the corner in the flood zone. We disagree with this. Should we receive flood insurance on the entire building?
 
Answer:
That is correct. Under the “one brick rule,” if the bank is taking the entire building as collateral and if even one corner or brick of the building is in the flood zone, the entire building must be covered. There’s not an exception for only securing the percentage of the building that is in the flood zone, unfortunately.
 
This was discussed in our latest flood webinar:
https://www.compliancealliance.com/news-events/an-in-depth-look-at-flood-insurance-webinar-2019
 
(a) In general. An FDIC-supervised institution shall not make, increase, extend, or renew any designated loan unless the building or mobile home and any personal property securing the loan is covered by flood insurance for the term of the loan. The amount of insurance must be at least equal to the lesser of the outstanding principal balance of the designated loan or the maximum limit of coverage available for the particular type of property under the Act. Flood insurance coverage under the Act is limited to the building or mobile home and any personal property that secures a loan and not the land itself.
https://www.ecfr.gov/cgi-bin/text-idx?SID=463dc6e6b10404e4021fd57c6eccf410&mc=true&node=se12.5.339_13&rgn=div8

Comments are closed.
    Picture

    Archives

    March 2020
    February 2020
    January 2020
    December 2019
    November 2019
    October 2019
    September 2019
    August 2019
    July 2019
    June 2019
    May 2019
    April 2019
    March 2019
    February 2019
    January 2019
    December 2018
    November 2018
    October 2018
    September 2018
    August 2018
    July 2018
    June 2018
    May 2018

    Categories

    All
    Compliance

    RSS Feed

    Compliance Alliance offers a comprehensive suite of compliance management solutions.

    To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com.
Copyright © 2023 Synergy by Association, Inc.  All Rights Reserved.
1149 Court Street NE  |  PO Box 13429  |  Salem, OR 97309  |  (800) 468-8558
Picture