On Oct 1, we received new knowledge that existing collateral is in a special flood hazard area. We sent out the required letter and notification at that time. The buildings were built in 2004 but our initial flood determination did not place them in a SFHA. The flood map was last revised after the buildings were built. A new LOMA is dated Dec. 1 & removes all buildings from the SFHA. Do we need to require flood insurance from Oct 1 to Dec 1?

Let me get this straight: You notified the borrower they had to get insurance on 10/1/16 (or shortly after) and now you have a LOMA dated 12/1/16? If that's correct, you may have had a small window of time that should have required insurance (45 days after you notified them), but not you know they don't need flood insurance. IOW, there may be a technical violation for not force placing during that window (11/15-12/1 at the most). I would let it go.

Thank you!