The Office of the Comptroller of the Currency, together with the Farm Credit Administration, Federal Deposit Insurance Corporation, Federal Reserve Board, and National Credit Union Administration, issued a joint reminder that lenders may continue to make loans subject to the federal flood insurance statutes when the National Flood Insurance Program is not available. During such a lapse, lenders may originate these loans without requiring federal flood insurance. The agencies pointed to Q&A Applicability 12 in the Interagency Questions and Answers Regarding Flood Insurance, which clarifies that institutions must still make flood determinations, provide timely, complete, and accurate notices to borrowers, and comply with other applicable requirements under the flood insurance regulations. Lenders are also expected to assess safety and soundness and legal risks and manage those risks prudently during the lapse period, and the guidance addresses the availability and use of private flood insurance.
Office of the Comptroller of the Currency 2025-10-01
Office of the Comptroller of the Currency and other federal regulators remind lenders they may continue flood statute loans when the National Flood Insurance Program is unavailable
The Office of the Comptroller of the Currency and other federal agencies reminded lenders they can continue making loans under federal flood insurance statutes even if the National Flood Insurance Program is unavailable. Lenders must still conduct flood determinations, provide accurate borrower notices, and comply with flood insurance regulations. The guidance also covers risk management and the use of private flood insurance during such lapses.