Would the flood insurance requirements apply to a loan secured by a building only, built on leased land? If it matters, the land is owned by the city. I'm leaning toward "yes" based on this definition of "designated loan" found in 12 CFR Part 22:
"(e) Designated loan means a loan secured by a building or mobile home that is located or to be located in a special flood hazard area in which flood insurance is available under the Act."
The definition does not refer to ownership of the land; it only refers to the location of the building as the determining factor.
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Opinions are mine not my employer's, and should not be taken as legal advice.