I've sent this question up through FEMA a couple of times in regard to a particular religious group. The group writes a general cooperative policy that includes flood coverage. After several requests for advice, with FEMA deferring to our regulator and our regulator deferring to FEMA, got advised that there just was not an exception. To substitute any coverage for the federal policy, it has to be comparable. This is usually an issue on cancellation, though we also had questions regarding the church group not being a licensed provider(they are exempt) and the "policy" being described as not being an insurance policy in the program description. Local examiners had not run into this before either. (Knowing that the bank down the street accepted the customer without further insurance while we were instructed not to was noted by both of us.) By the way, we did have the loan for one year with a force placed federal policy. The customer found they could do better elsewhere. As noted above, it was unusual to first, be making a loan to a member, and second, to have buildings in a flood zone.