FirstBank pays $172,500 flood insurance penalty

On March 30, 2021, the FDIC assessed a civil money penalty of $172,500 on FirstBank, Nashville, Tennessee, for engaging in a pattern or practice of committing violations of violations of Part 339 of the FDIC Rules and Regulations, 12 C.F.R. Part 339, which implements section 102 of the FDPA, 42 U.S.C. § 4012a, having found that the bank—

• violated section 339.3(a) of the FDIC Rules and Regulations, 12 C.F.R. § 339.3(a), by failing to obtain flood insurance coverage at or before loan origination, increase, renewal, or extension on sixty-one (61) instances.
• violated section 339.7(a) of the FDIC Rules and Regulations, 12 C.F.R. § 339.7(a), by failing to maintain an adequate amount of flood insurance for the term of the loan in eighty-eight (88) instances and failing to provide the required force-place flood insurance notice to the borrower within forty-five (45) days of force placement in ten (10) instances
• violated section 339.9(c) of the FDIC Rules and Regulations, 12 C.F.R. § 339.9(c), by failing to provide a Notice of Special Flood Hazards and Availability of Federal Disaster Relief Assistance timely in thirty-seven (37) instances