Product Update Blog

Product Updates for March 2019

The Product Updates for March 2019 from feature the following revised policy template products:

Flood Disaster Protection Act Policy Template

The update to this product is in response to the Joint Press Release entitled “Interagency Final Rule Implements Flood Insurance Reform Provisions” dated February 12, 2019 that announced a joint final rule to implement provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 requiring regulated institutions to accept certain private flood insurance policies in addition to National Flood Insurance Program policies.

The rule, which takes effect July 1, 2019:

  • Implements the Biggert-Waters Act requirement that regulated lending institutions accept private flood insurance policies that satisfy criteria specified in the Act;
  • Allows institutions to rely on an insurer’s written assurances in a private flood insurance policy stating the criteria are met;
  • Clarifies that institutions may, under certain conditions, accept private flood insurance policies that do not meet the Biggert-Waters Act criteria; and
  • Allows institutions to accept certain flood coverage plans provided by mutual aid societies, subject to agency approval.

Regulations implementing the federal flood insurance statutes prohibit regulated lending institutions from making loans secured by improved real property located in special flood hazard areas unless the property has adequate flood insurance coverage.

We updated the following policy template products in various degrees to reflect a reference to the new Current Expected Credit Losses (CECL) accounting standard. Most of the changes are relatively minor in nature, such as using a more generic term of “allowance for credit losses” rather than “allowance for loan and lease losses” or “ALLL” for those of our clients who choose to adopt the CECL accounting standard early as of July 1, 2019.  In this regard, both ALLL and CECL related guidance remains within our applicable templates.

As a reminder, we will continue to revise our products to reflect recently released regulatory guidance regarding CECL when and where applicable, and will notify our client base via e-mail and on our Product Update Blog on our website of their public release.

Keeping You Informed

We provide this Product Update Blog as a courtesy to all clients regarding new and revised products released by  We feel that it is important to keep our clients well informed of changes to the financial institution industry, including keeping on top of federal regulatory changes, and industry recommended best practices.  In this regard, we encourage you to subscribe to our newsletter in which these types of announcements are made including any special offers that can save you time and money.  Just contact us to be added to our distribution list.

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