Most lenders make flood hazard determinations themselves or use the services of a Flood Zone Determination Company ( FZDC ).
Caution #1, The determination should always be made on the insurable structure and not just a portion of the property being located in a SFHA. If a lender transfers a positive decision from a determination company to Section D of FEMA's Standard Flood Hazard Determination Form and the initial determination was made on a portion of the property and not the structure, a grievous error has been made. You may require flood insurance that is not necessary.
Caution #2, When positive determinations are made on the structure, lenders should provide a disclaimer to notify borrowers about FEMA's appeals processes which can change the zone of location and/or mandatory flood insurance purchase requirement.
The point of cautions 1&2 is to protect the lender. Mr. Smith pays A zone flood premiums based upon the lender's use of a determination company's positive determine. Ten years later, Mr. Smith finds out that while a portion of his property is in the SFHA, the structure is not or the structure will qualify for a Letter of Map Amendment (LOMA) releasing him from the mandatory flood insurance purchase requirement. After paying $6000 to $8000 in unnecessary flood insurance premiums, Mr. Smith is now looking for a total refund from someone and will most likely contact his attorney. A disclosure by the lender can provide protection since you made the borrower aware of the appeals process with the initial determination.
Lenders who use a C.F.M.
in in private practive for flood zone determinations can be assured of
receiving accurrate results with the following advantages:
Determinations are based upon the location of the structure and not just
the tax map parcel where possible.
Positive determinations can be reviewed based upon expanded information
sources.
Flood Hazard Appraisals conducted on site can verify determination results,
flood insurance premium rating, and qualifications for successful appeals
- Letters of Map Change ( LOMC ).
Discolsure of the information upon which a determination was based.
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| File last modified on October 2, 2001. |