Have a customer who has an existing loan with us, requesting a new loan to construct a new building on the property. Existing loan/determination is about 1 year old, using same property as collateral.

We can rely on the existing determination, correct? Or, since this will be a new structure, will I need to request a new determination?

You have a MIRE event, so a new determination is required.

Not necessarily, IMHO. If the determination is less than 7 years old and the flood maps haven't changed the existing determination may be utilized per regulation. It also depends on your bank policy, etc.

Agree with Skittles.

I'll 3rd that. the only other comment I'll make would be that it will only be okay if none of the property was in a designated zone. If any part was, you will need to verify that the new building is not in it.

But its a new loan, correct? So you have a MIRE event which requires a new determination.

Although it's worded oddly, the last sentence of QA 68, IMHO, speaks to the ability to reuse:

https://www.bankersonline.com/sites/default/files/tools/flood_faq_2011_10_17.pdf

68. May a lender rely on a previous determination for a refinancing or assumption of a loan or multiple loans to the same borrower secured by the same property?
Answer: It depends. Section 528 of the Act, 42 U.S.C. 4104b(e), permits a lender to rely on a previous flood determination using the SFHDF when it is increasing, extending, renewing, or purchasing a loan secured by a building or a mobile home. Under the Act, the “making” of a loan is not listed as a permissible event that permits a lender to rely on a previous determination. When the loan involves a refinancing or assumption by the same lender who obtained the original flood determination on the same property, the lender may rely on the previous determination only if the original determination was made not more than seven years before the date of the transaction, the basis for the determination was set forth on the SFHDF, and there were no map revisions or updates affecting the security property since the original determination was made. A loan refinancing or assumption made by a lender different from the one who obtained the original determination constitutes a new loan, thereby requiring a new determination. Further, if the same lender makes multiple loans to the same borrower secured by the same improved real estate, the lender may rely on its previous determination if the original determination was made not more than seven years before the date of the transaction, the basis for the determination was set forth on the SFHDF, and there were no map revisions or updates affecting the security property since the original determination was made.

Thanks RR. We have always taken the stance of pulling a new determination, but I understand the above.

To be honest, more often than not, we would too

Thanks everybody, I appreciate the help! I was told by our vendor that since this would be a new structure, a new determination is needed. And yes, part of the property is in a flood zone, and part out.

And yes, part of the property is in a flood zone, and part out.

By property, do you mean "buildings/structures" or land. There is no issue, and no insurance required if only the land is in a flood zone.

I believe that is yet to be determined, based on the full story

Though not necessarily required, we always pull a new determination for each new loan. If we have one determination that is used for two loans, we run the risk that someone may cancel the determination when one of the loans pays off. If that happens we won't be notified if there is a zone change on the property that affects the other loan.

Rocky, there are multiple structures on the land, some are in the flood zone, some are out. The "property" in question is land, but where a new structure will be built.