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#2223327 - 10/08/19 06:07 PM Flood Determination - Multiple Buildings
TeamComply Offline
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Joined: Aug 2016
Posts: 393
Auditing loan files for flood compliance....there is a property located at 123 N. Main St. - it consists of 6 apartment buildings, and 1 office building. One determination was ordered (prior to loan origination) for the subject address and it indicates property is in a flood zone. Bank then determined by looking at flood map (from FEMA) and the appraisal in the loan file, that only one building on the property is in a flood zone. In looking at FEMA's flood map for this property, it is difficult in my opinion, to say without a doubt, that all of the other 6 structures are not located in the flood zone. Will this really fly with examiners? Or do we need something more concrete stating whether or not each building/structure on the property is or is not located in a flood zone? Should a determination outlining the flood zone status for each building have been obtained? Loan closed several month ago, so wondering what exactly needs to be done (if anything) at this point, I just don't want us to be criticized by examiners for any of this. Help please!

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Flood Compliance
#2223339 - 10/08/19 06:51 PM Re: Flood Determination - Multiple Buildings TeamComply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 77,239
Galveston, TX
Have your FHD provider do an aerial overlay.
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#2223344 - 10/08/19 06:58 PM Re: Flood Determination - Multiple Buildings TeamComply
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Think about an agricultural loan where you have a 160 acres, the house/farm yard and maybe grain bins ΒΌ mile away. One SFHDF can be used to represent the entire property. I see them all of the time.

Now if some of the buildings are in a SFHA and some aren't, it can be confusing to say "yes" or "no" on one SFHDF. As Randy mentioned, an aerial overlay can provide clarity.
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David Dickinson
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