FEMA says that you can charge a fee for initial flood determinations provided they are bona fide and reasonable. Regulation Z 226.4(c)(7)(iv) includes fees related to flood-hazard determinations...provided they are bona fide and reasonable in amount. As long as the fee is reasonable and involves an initial determination there are no Reg Z issues.
This is my opinion and not that of my employers.
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Allan D. Virr, CRCM,CRP
Compliance Audit Solutions, LLC