Horicon Bank pays $23K for flood insurance violations

The FDIC issued a Consent Order to Pay a Civil Money Penalty of $23,000 to Horicon Bank, Horicon, WI. The FDIC determined that the Bank had engaged in a pattern or practice of committing violations of the Flood Disaster Protection Act , the notice requirements under section 1364 of the National Flood Insurance Act of 1968, 42 U.S.C. § 4104a, and Part 339 of the FDIC’s Rules and Regulations, 12 C.F.R. Part 339 as follows:

• section 339.3(a) of the FDIC Rules and Regulations, 12 C.F.R. § 339.3(a), by failing to obtain flood insurance on a building securing a designated loan at the time of the origination of two (2) loans;
• section 339.3(a) of the FDIC Rules and Regulation, 12 C.F.R. § 339.3(a), by failing to obtain adequate flood insurance at the time of the origination of four (4) loans;
• section 339.3(a) of the FDIC Rules and Regulation, 12 C.F.R. § 339.3(a), by failing to provide to borrowers a Notice of Special Flood Hazard and Availability of Federal Disaster Relief Assistance when making, increasing, extending or renewing a loan on twenty-four (24) occasions;
• 12 C.F.R. § 339.5, by failing to require the escrow of all premiums and fees for required flood insurance when it required the escrow of taxes, insurance premiums, fees, or any other charges for a loan secured by residential improved real estate for five (5) loans.