We last had major flood map revisions in our lending area in 2007, at that time we were still checking flood maps manually and did a massive scrub of our files to determine whether any properties were put in or taken out of the flood zone. In 2011, we began using a flood determination provider and have obtained LOL monitoring on any determinations obtained since that time. We are aware of significant flood map changes coming in our lending area later this year. So our question is, for those loans on our books since 2007 through 2011 that have not had a MIRE event, must we pull new flood determinations with LOL coverage once the map changes become effective? Is knowledge of the map change itself an event triggering us to obtain new flood determinations for those properties in our portfolio that don't already have LOL flood monitoring coverage? Or if we have a manual flood determination (obtained in 2009, for example) and we have a triggering MIRE event, is that the first we would need to obtain a new flood determination? Wondering if we need to do a massive scrub of all of the old manual files once we have knowledge that flood maps have changed. Thoughts or suggestions please. Thanks.

If you don't have LOL then you would wait for a MIRE. Unless you wanted to do something from a safety and soundness perspective.

Randy is correct that you can wait until a MIRE event. There are also "trip wires" like knowledge of a map change. Like Randy said, if you don't have a Life of Loan service, you may not know that a map change effected a property you have as collateral. I've seen many examiners that expect you to know. If you do have knowledge of a map change, it's difficult to argue "I didn't know". It really depends on how much knowledge you have of the map changes, your borrowers and their collateral.

I don't believe you need to do a massive scrub. IOW, you don't need to create knowledge. However, if you know a property is now in a SFHA that wasn't before the map change, I don't believe you can stick your head in the sand and ignore it waiting for a MIRE event.