WASHINGTON—NAFCU and CUNA have joined with a number of other financial services trade associations in a letter regarding FEMA’s proposed revisions to the Standard Flood Hazard Determination Form.
The letter, sent to FEMA, the Office of Information and Regulatory Affairs (OIRA), and the Office of Management and Budget (OMB), offers several additional recommendations the associations want to be considered. Among those recommendations:
- Remove ambiguity as to the Form’s length—Form should remain a single-page form. “For more than 20 years, this Form has been a single page with accompanying official instructions to guide the preparer and user in completion and use of the Form…,” the letter states. “The revised version of the Form appears to be a multi-page document inclusive of instructions and a final data collection page. We strongly urge FEMA and the OMB to revise the document as described below to be consistent with the Form’s format for 20 years.”
- Remove the word “(continuation)” from the Form’s header. “Any revision to the Form requires implementation time for preparers, lenders, and servicers to update electronic forms, processes, and systems,” the letter states. “Therefore, we request that the final notice related to the issuance of the revised version of the Form specifically mention that the currently effective version of FEMA Form 086-0-32 continues to remain effective and valid for 6 months from May 30, 2015.”
- Format should remain flexible. “Historically, preparers and users of the Form were given flexibility with regard to the non-material format of the Form, provided the required data was being collected,” the groups said. “We request that the final notice related to the issuance of the Form expressly permit such flexibility
In addition to CUNA and NAFCU, the letter was signed by the American Bankers Association,Consumer Bankers Association, Consumer Mortgage Coalition, Independent Community Bankers of America, Mortgage Bankers Association, and National Flood Determination Association.