On Dec. 10, the MCUL & Affiliates provided its comment letter to the NCUA regarding the Interagency Proposal addressing loans in areas having special flood hazards. The proposed rule addresses amendments to the National Flood Insurance Program as amended in the Biggert-Waters Act specifically:
MCUL was generally supportive of the requirements addressed in the proposal, however MCUL asked the agencies to be cognizant of the current regulatory burdens credit unions are facing and be mindful of placing additional regulatory requirements on credit unions. MCUL also asked the agencies to consider extending the effective date of compliance or provide for a waiver in the event a compliance date cannot be met.
The MCUL’s Comment Letter can be found here.