Citibank pays $18M in Flood Act penalties

The OCC has issued a Consent Order to Citibank, N.A., Soiux Falls, South Dakota, under section 102(f) of the Flood Disaster Protection Act ("Flood Act") for a pattern or practice of violations of the Flood Act and its implementing regulations, 12 CFR 22.7(a).

The OCC found that:—

1. as part of its Flood Act compliance program, the Bank utilized a third-party to service Designated Loans within its residential lending units to notify the borrowers and force place flood insurance when the flood insurance failed to appropriately cover the Collateral.
2. the Bank’s policies and procedures allowed its third-party servicer to extend the 45-day period after notification to the borrower resulting in the untimely force placement of flood insurance on Designated Loans.
3. since at least 2014, the Bank failed to force place insurance in a timely manner on residential Designated Loans and engaged in a pattern or practice of violations of the Flood Act and its implementing regulations, including 12 C.F.R. § 22.7(a) (Force placement of flood insurance).