I've seen this topic discussed in a number of threads, but I thought it has generated enough confusion that it deserved its own thread. My question involves reusing old flood determinations. I've read the previous threads and David's article from bankerscompliance.com and still have a question about life of loan and its impact on reusing old determinations.

I know that there is a difference between life of loan monitoring services with some services notifying you only if your loan is affected (out to in, in to out) whereas other services will notify you everytime a map is updated. Our vendor will update us everytime there is a map change regardless of its impact on our loan. When there is a map change the original flood determination is then updated to reflect the new flood map and the date of determination is updated as well. Does this type of service allow us to reuse old flood determinations if they are less than 7 years old? The confusion for me is that technically, a new or revised map has been issued since the original determination was made so it seems like we would need to order a new determination. That being said the original determination is automatically updated to reflect the map change so in a sense it is a new determination. I think the confusion comes from a rule that was written without taking into consideration life of loan monitoring. I'm very interested to hear what others think.

As longer as your FHD form in file references the current map, you would be OK. I don't know what you mean by "original flood determination is then updated to reflect the new flood map".

I think the confusion comes from a rule that was written without taking into consideration life of loan monitoring.
Your right. When thinking about the regulatory requirements, forget about this service. It's for your benefit, but it doesn't cancel any regulatory requirement.

When there is a map change the original flood determination is then updated to reflect the new flood map and the date of determination is updated as well.
Then you have a new (updated and newly dated) SFHDF. You should be able to rely on it for subsequent loans for the next 7 years, if nothing else changes.

However, the Flood Insurance Act requires the SFHDF to be guaranteed for the lender [42 U.S.C. §4104(b)(d)]. Does your vendor allow you to use a SFHDF for Loan A and not pay them again to use it for Loan B? If not, then they don't guarantee the accuracy of the SFHDF for Loan B and you aren't compliant.

Clark: You probably posted without seeing my reply. I don't think the determination # matters. That's not a required item and used for record keeping by the vendor. I'll stick with my answer.

Thank you both for the responses.

Randy, what I meant by the original determination being updated is simply that the map and date are updated, but the determination keeps the same number. We don't order or go pull a new one.

David, I remember reading abou that requirement, but hadn't considered it until now. I will reach out to the vendor and find out. Part of me is skeptical that they would guarantee the accuracy of both without charging again, but that price may be built into the service; that relatioship pre dates mine at the bank.