WASHINGTON (9/23/09)--In a comment letter responding to recent changes to federal regulators’ questions and answers regarding flood insurance policies, the Credit Union National Association (CUNA) said that some proposed changes to loan participations may “represent an inappropriate shifting of risk” from the original lender to entities that have assumed some control of a property. CUNA said that it has “no objections” to Q&As addressing replacement cost valuations “for property that will not be restored to its original purpose.” CUNA also found no issues with Q&As addressing force-placed insurance. However, Q&As addressing loan participation set unreasonable standards by forcing lenders that buy a participation interest in a loan on flood zone-based property to be responsible for ensuring that flood insurance requirements are met. CUNA also opposed shifting risk and responsibility surrounding the validity of flood insurance from loan originators to those who purchase participations in exiting loans. Use the resource link below to read CUNA's complete remarks.