Based on a flood determination for a pending loan we have a property that is located in a flood hazard area. The customer has indicated that they have documentation that the elevation has been raised and is no longer subject to flooding. The customer is going to appeal the flood determination with FEMA. Our loan is closing mid-April don't we have to have flood insurance in place before closing even if we have knowledge that the customer is appealing the determination???

Until you receive a LOMA or LOMR, flood insurance is required. If they want to close the loan and a determination has not been made, you will have to have the proper amount of insurance prior to closing.

It is fairly easy to determine if a LOMR or LOMA has been issued for a given flood map panel. If you know the NFIP Community Number and the Map Panel (from the flood determination), you can use the FEMA web site to check and see if a LOMR or LOMA is active on that panel. Feel free to send me a private message and I can walk you through it in more detail.

What documentation does the customer have? They may already have a copy of the LOMR/LOMA. We have had a few situations where FEMA issued a LOMR several years ago, but for some reason the company we use for determinations don't pick it up!