The current instructions on the SFHDF read: MULTIPLE BUILDINGS: For guidance regarding multiple buildings, please contact your regulator, servicer, lender or other entity as applicable.
Previous versions read: MULTIPLE BUILDINGS: If the loan collateral includes more than one building, a schedule for the additional buildings/mobile homes indicating the determination for each may be attached. Otherwise, a separate form must be completed for each building or mobile home. Any attachments should be noted in the comment section. A separate flood insurance policy is required for each building or mobile home.
I am not aware of any specific guidance from the individual regulators on this issue.
Not unusual for a private umbrella policy to be in place if the value of the structures support it. You still have to consider the maximum available insurance for the apartment buildings is $500,000 in your calculations and if need to make your minimum flood insurance number that the private policy is acceptable to the bank..
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