With the stiff penalties that can be levied for non-compliance with the flood rules, the bank has taken a stance that each time a loan with buildings is granted or refinanced that we will pull a new flood determination and have the notice signed by the borrower (even if the property is not in a SFHA). For properties where we had a previous determination, the re-order is only a few bucks.

I'm wondering if we are overkilling it. We have thousands of properties as collateral but only about 75 flood properties. Does anyone have any proven methods that works for them to make sure that you stay in compliance with the flood rules regarding the notification requirements (among others).

I would like to be able to save the bank some $$ by not reordering determinations when not necessary and to reduce LO headaches by requiring the notice to be signed when really it only has to when the property is in a SFHA but I don't have confidence at this point.

At my former bank we reviewed the previous flood cert and compared the flood map number to the FEMA website (free). If the map number did not change and the cert was < 7years old, we did not pull a new flood. We imaged a copy of the FEMA results and documented the file. If the map number changed, we pulled a new flood cert and charged the customer.

I don't think pulling a new flood cert is necessarily overkill, but mandating signed flood notices for properties not in a flood zone seems like overkill to me.

You might check with your flood cert vendor. We are able to re-certify our flood certs, at no charge. The vendor checks the current maps and makes whatever adjustments are needed to the original certification. The certification is marked re-certified and the date of re-certification.