Its always hard to come back to work after a vacation!!

Anyway, we have some flood determinations done prior to our last compliance exam that were not done by a certified company or person, they were done inhouse by a loan officer. We were not told to fix them in any exams since. Do you think we should have a certified company redo these flood determinations or should we just fix all incorrect ones done after our last exam?

What needs to be fixed? As long as the determinations are recorded on the SFHDF there is nothing wrong with you doing internal determinations.

If you are wanting to get these into your portfolio reviews for LOL monitoring then it would be advisable to get new FZDs.

"Incorrect" is the key word. If they were done in-house or out-sourced, it wouldn't matter. I'd fix what is wrong, regardless of when they were done.

Someone is considering the fact that examinations review transactions since the last exam. But if you have civil liability here, the last regulatory exam is meaningless and you have risks. Mitigate those risks. If you have property you show as "out" of a SFHA and they are actually "in", get coverage. Similarly, if the reverse is true, how was the policy issued and does it need to continue?

Fix - as in they were not correct? There is no regulatory requirement that you use another company - certified or not - to do your flood determinations. You can do them in-house if you so choose, unless required by the secondary market.

Hey - it's the RAD team You know, Randy, Andy and Dan. Not that I deserve to go first, but DAR, DRA, RDA, ARD or ADR just didn't seem to work as well

Do you deal with "Life of Loan" monitoring on the flood certifications that you obtain at origination? Is your concern over the possibility that flood map revisions after origination may have impacted flood insurance requirements on a loan-by-loan basis?