We have a customer with a deck off the back of their home. A corner of the deck is affected by Flood Zone A, per the aerial maps provided by our flood determination provider.

The customer is stating that his insurance company says he doesn't need flood insurance as it's only his deck affected.

It seems we have had a similar scenario in the past, however I am unable to locate guidance that addresses this. Any input or direction to guidance on this specific issue would be appreciated.

Thanks!

I have nothing to support my opinion, but it's a deck. It's an accessory structure to the house. I wouldn't require it under mandatory rules. Your institution may consider requiring insurance as a risk mitigation option.

If the deck is not attached to the house, it would not be part of the building (and not considered a structure requiring flood insurance). If the deck IS attached to the home, it would be considered part of the building. If any part of the "building" (foundation) is located in a flood zone, the entire building is considered to be in a flood zone.

The (now rescinded) Mandatory Flood Purchase Guidelines explained this pretty well.
"Even though a portion of real property on which a building is located may lie within an SFHA, the purchase and notice requirements do not apply unless the building itself, or some part of the building, is in the SFHA. However, even if that part of the building within the SFHA is not subject to coverage (e.g., a deck), the entire building is considered to be in the SFHA."

Also, the flood insurance manual explains this and also explains that it depends on where the foundation is located, not necessarily where it overhangs:
"D. Buildings in More Than 1 Flood Zone/BFE
Buildings, not the land, located in more than 1 flood zone/BFE must be rated using the more hazardous zone/BFE.

This condition applies even though the portion of the building located in the more hazardous flood risk zone/BFE may not be covered under the SFIP, such as a deck attached to a building. (Example: The building must be rated using the more hazardous flood risk zone/BFE if any portion of the attached deck foundation extends into the more hazardous flood risk zone/BFE. If the attached deck overhangs the more hazardous flood risk zone/BFE, but its foundation system does not extend into more hazardous flood risk zone/BFE, then the building must be rated using the flood risk zone/BFE where the building foundation is located.)"

The full flood manual can be found here: https://www.fema.gov/media-library-data/20130726-1851-25045-7384/oct2012_fullmanual.txt

Thank you for your reply!