Scenario:

Loan secured by MFH without land closes 11/03 in husband & wife's name. Zone is X.

Husband dies and wife finds a new husband. 97 payments remain.

Loan is modified on 11/16/10 taking off deceased husband and adding new husband. Maturity is extended to make it 108 payments remaining.

A new flood was NOT pulled, but should have been...correct?

You didn't have to pull a new one, unless required by your LOL monitoring company for tracking purposes...however, you needed to make sure the map didn't change.

Well, our typical method of documenting that it didn't change is to order a new one. So, should I order a new one now (which will jump out like a red flag), or is there another way we can find out?

YOu can look it up yourself and see if it changed or not...then note on the form 'no change as of xx date'.

However if the first flood determination was pulled in November 2003 it's over 7 years old and a new determination is required.

Point!

::teach me to skim right over the date!::

Just so I understand this correctly......would we have been required to pull a new flood if we were not extending the term of the loan?

If you touched it (MIRE) you hit a trigger. Since it was modified to change names, then you hit a trigger regardless of extending the term.

Okay....so all we can do now is order a new flood (even though it is after the fact).

I would.

I would have to opine they can rely on:

same property + same lender = existing determination providing all 3 factors are met. Less than 7 years old, on the SFHDF and there have been no map changes.

PS. The following will give you the current map and it is updated daily.

http://www.fema.gov/fema/csb.shtm

(it was over 7 years)

Ditto - at least I put the statement "providing the 3 factors are met". I guess that's a bit of a saving grace.

yup..you definitely did better than I did!

I have a question regarding this topic...Do I understand this all to mean that even if you have LOL through the flood vendor and you are extending the term that either you must order a new cert or check the flood map and document yourself?

Sorry everything starts to run together this time of day!

Do I understand this all to mean that even if you have LOL through the flood vendor and you are extending the term that either you must order a new cert or check the flood map and document yourself?

Yes.

Life of loan meets no regulatory requirements. It is a service to your bank. That's it.

You must still fully comply with the Flood requirements. If you make, increase, renew or extend a loan, you must pull a new SFHDF or rely on an old one if the 3 conditions are met.

I have a lender that wants to use an old flood determination to refinance the current loan and add money to it. All 3 of the conditions are met. The loan will be paid off before the seven years. I want to tell the lender no that they should oder a new one because there needs to be continued monitoring of the property. Am I correct on this or not? Appreciate any help

There is no regulatory requirement to have life of loan monitoring. It is purely an investor requirement. The seven year period for use of an old FHD is at the beginning of the loan, not for the life of the loan.

Thanks Randy