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Flood Compliance & Master Certifications
Answer by Dan Persfull, BOL Guru
Guru Bio
Question: On construction starts to builders for multiple lots, is a master certification for flood determination within compliance? In my banking history in the residential construction lending area, banks historically used master certifications. Most banks use companies such as TransUnion settlement solution for flood certification. When ordering a master certification you send a legal description, plat and survey, plus the recorded plat and section. In my past experience with other banks this was fine. You keep the recorded plat in file along with the flood determination and the multiple lot (master certification) for documentation. I contacted TransUnion for further clarification and was told that this form of certification is used by multiple banks and is acceptable. I believe that the flood certification company is liable for correct flood determination. When the house is complete and sold to an individual, then it is the responsibility of the lending institution to order an individual flood determination. We are a young bank and wish to make sure we remain in compliance on flood determinations. Your expertise and input to this question is appreciated.
Answer: I am not familiar with this type of a determination. However, on page 38 of the 2007 release of the Mandatory Purchase of Flood Insurance Guideline book it speaks to the fact that a SFHDF is required for each adjacent property. Therefore if each of these lots have been plated out with their individual legal description then I would opine they are adjacent properties and would require a SFHDF for each property. If the lots have not yet been plotted out into their own "parcel" then I would think your "master certification" would suffice until the the individual lot is plotted out of the overall parcel of land. Again, I have no experience with "master certifications" and the above is my opinion.
First published on BankersOnline.com 4/28/08

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