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Compliance

Florida Legislative Updates – Flood Insurance Requirements for Citizens

Starting April 1, 2023, Florida Law (Fla. Stat. §627.351(6)(aa)) will mandate new flood insurance requirements for property owners purchasing personal lines residential risk insurance through Florida’s Citizens Property Insurance Corporation (Citizens), the state’s Fair Access to Insurance Requirements (FAIR) plan. Property owners submitting new Citizens applications for policies that include wind coverage will be required to purchase and maintain flood insurance if the insured property is located in a special flood hazard area (SFHA) designated by National Flood Insurance Program. For existing Citizens policyholders, the new requirement will apply to renewal policies issued on or after July 1, 2023.

 

Starting in 2024, flood insurance will be required to be obtained and maintained in connection with all Citizens personal lines residential risk policies, regardless of flood zone. The flood insurance requirement will be implemented according to the following timetable:

 

  • January 1, 2024, for policies insuring property to a limit of $600,000 or more.
  • January 1, 2025, for policies insuring property to a limit of $500,000 or more.
  • January 1, 2026, for policies insuring property to a limit of $400,000 or more.
  • January 1, 2027, for all other policies.

 

Policyholders whose policies issued by Citizens do not provide coverage for the peril of wind are not required to purchase flood insurance as a condition of their policies.

 

All policyholders impacted by this new rule will be required to sign a Policyholder Affirmation Regarding Flood Insurance (CIT FW01). The law allows flood policies to be purchased from either the NFIP or a private flood insurance carrier.  Additional updates regarding the new rules, forms and changes published by Citizens can be found here.

 

The new law does not impose any direct obligations on lenders or servicers with respect to tracking flood insurance coverage. If you have questions regarding potential impact to your entity’s business rules, please reach out to your relationship manager. The BBVA Insurance Compliance Team will continue to monitor this topic and provide updates as applicable.