On May 17, the Federal Reserve announced the execution of a settlement agreement with a state bank resolving alleged violations of the National Flood Insurance Act (“NFIA”), 42 U.S.C. § 4012a(f), and Regulation H, 12 C.F.R. part 208. The Board of Governors asserted that where a pattern or practice of violations of the NFIA is found, civil money penalties can be imposed up to $2,000 per violation. To resolve the enforcement actions, the bank consented to a civil money penalty of $27,285. The bank did not admit any wrongdoing and the agreement was entered without any finding on any issue of fact or law.
