The most recent issue of the Federal Reserve publication Consumer Compliance Outlook features an article on lender-placed flood insurance. The article provides guidance on FEMA’s change in the waiting period requirements for lender force-placed insurance using the Mortgage Portfolio Protection Program (MPPP). It also addresses Section 100244(a)(1) of the Biggert-Waters Act, which “permits lenders to purchase force-placed insurance beginning on the date that a lender determines a property lacks coverage or the amount of coverage is insufficient, and it permits lenders to pass the cost of that force-placed insurance along to the borrower, including any associated fees.”
ABA urges FHA to revise RAP demonstration before launch
ABA expressed support for FHA's proposed voluntary Reinstatement Advance Payment, or RAP, demonstration, but also offered several recommendations to ensure mortgagees are fully equipped to participate in the demonstration and borrowers are treated fairly and consistently.








