# FDIC FIL-61-2020: The FDIC Updates its Enforcement Actions Manual for Flood Insurance Civil Money Penalties > Federal · Agency guidance · In force URL: https://www.frixlaw.com/law-library/statutes/FDIC_FIL20061 ## Section - **Citation:** FDIC FIL-61-2020 - **Heading:** The FDIC Updates its Enforcement Actions Manual for Flood Insurance Civil Money Penalties - **Jurisdiction:** Federal - **Kind:** Agency guidance - **Status:** In force - **Text as of:** August 14, 2026 - **Source:** Compiled text - **Location:** FDIC Financial Institution Letters / The FDIC Updates its Enforcement Actions Manual for Flood Insurance Civil Money Penalties ## Text The FDIC Updates its Enforcement Actions Manual for Flood Insurance Civil Money Penalties June 18, 2020 Share on Facebook Share on X Share on X Follow the FDIC on LinkedIn Share through email Print Summary: The FDIC has updated its Formal and Informal Enforcement Actions Manual (manual) regarding the assessment of mandatory civil money penalties (CMPs) for certain pattern and practice violations of the National Flood Insurance Act of 1968, as amended by the Flood Disaster Protection Act of 1973, as revised, 42 U.S.C. § 4012a (Flood Act) and Part 339 of the FDIC Regulations. The manual provides direction for professional staff related to the work necessary to pursue formal and informal enforcement actions. It is also intended to support the work of field office, regional office, and Washington office staff involved in processing and monitoring enforcement actions. Statement of Applicability to Institutions with Total Assets Under $1 Billion: This Financial Institution Letter (FIL) applies to all FDIC-supervised financial institutions. No action on the part of any insured depository institution is necessary. Highlights: The Flood Act requires the FDIC to assess a penalty of up to $2,000, adjusted annually for inflation, per violation per loan against an insured depository institution (IDI) for certain pattern and practice violations of the Flood Act. When calculating the appropriate amound of mandatory Flood Act CMPs, the FDIC will generally use a two-step process by determining a base CMP and adjusting the base CMP for smaller institutions with reduced ability to pay such penalties. The base CMP takes into account the type and repeat nature of the violations. The Institution Asset Size Factor takes into account the institution’s asset size based on the last Call Report prior to the date of the examination. This CMP framework is consistent with statutory authority under the Flood Act nd adjusting the base CMP for smaller institutions with reduced ability to pay such penalties. The base CMP takes into account the type and repeat nature of the violations. The Institution Asset Size Factor takes into account the institution’s asset size based on the last Call Report prior to the date of the examination. This CMP framework is consistent with statutory authority under the Flood Act. While the steps and charts are tools to establish an appropriate CMP when pattern and practice violations of the Flood Act are identified, the FDIC maintains its discretion to consider the facts and circumstances of each case when determining the amount of the CMP. Suggested Distribution: FDIC-Insured Institutions Suggested Routing: Chief Executive Officer Chief Compliance Officer FIL-61-2020 Attachment(s) Formal and Informal Enforcement Actions Manual Homeowner Flood Insurance Affordability Act of 2014 Biggert-Waters Flood Insurance Reform Act of 2012 Flood Disaster Protection Act of 1973 FDIC Law, Regulations, and Related Acts Consumer Compliance Examination Manual Contact(s) Denise Beiswanger , (605) 333-2051 x8620 FDIC: Office of the Ombudsman , (877) 275-3342 ## Nearby sections - [FDIC FIL-1-2002 FOREIGN ASSETS CONTROL ACT](https://www.frixlaw.com/law-library/statutes/FDIC_FIL02001.md) - [FDIC FIL-1-2010 Employee Compensation Advance Notice of Proposed Rulemaking](https://www.frixlaw.com/law-library/statutes/FDIC_FIL10001.md) - [FDIC FIL-1-2015 DEPOSITORY INSTITUTION REPORTS](https://www.frixlaw.com/law-library/statutes/FDIC_FIL15001.md) - [FDIC FIL-1-2018 DEPOSITORY INSTITUTION REPORTS](https://www.frixlaw.com/law-library/statutes/FDIC_FIL18001.md) - [FDIC FIL-1-2024 Consolidated Reports of Condition and Income for Fourth Quarter 2023](https://www.frixlaw.com/law-library/statutes/FDIC_FIL24001.md) - [FDIC FIL-2-2019 DEPOSITORY INSTITUTION REPORTS](https://www.frixlaw.com/law-library/statutes/FDIC_FIL19002.md) - [FDIC FIL-2-2020 Consolidated Reports of Condition and Income for Fourth Quarter 2019](https://www.frixlaw.com/law-library/statutes/FDIC_FIL20002.md) - [FDIC FIL-3-2017 Community Banking Conference 2016 Highlights](https://www.frixlaw.com/law-library/statutes/FDIC_FIL17003.md) - [FDIC FIL-4-2015 The FDIC Launches Web Page to Support Marketing of Failing Financial Institutions](https://www.frixlaw.com/law-library/statutes/FDIC_FIL15004.md) - [FDIC FIL-4-2018 Revisions to the Consolidated Reports of Condition and Income (Call Report) for March and June 2018](https://www.frixlaw.com/law-library/statutes/FDIC_FIL18004.md) - [FDIC FIL-4-2019 Banker Webinar: Update on the Standardized Export of Imaged Loan Documents Initiative](https://www.frixlaw.com/law-library/statutes/FDIC_FIL19004.md) - [FDIC FIL-4-2021 Revised Guidelines for Appeals of Material Supervisory Determinations](https://www.frixlaw.com/law-library/statutes/FDIC_FIL21004.md) - [FDIC FIL-4-2023 Guidance to Help Financial Institutions and Facilitate Recovery in Areas of California Affected by Severe Winter Storms, Flooding, Landslides and Mudslides](https://www.frixlaw.com/law-library/statutes/FDIC_FIL23004.md) - [FDIC FIL-4-2025 FDIC Statement of Policy on Bank Merger Transactions](https://www.frixlaw.com/law-library/statutes/FDIC_FIL25004.md) --- Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/FDIC_FIL20061. Check the current official text before relying on it. Not legal advice.