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#2264653 - 01/12/22 03:39 PM 40 Flood determinations or one?
JacksTigger Offline
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JacksTigger
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lost in compliance land
Condo building with 55 units NOT in Flood Zone. All condos are in one building. Borrower owns 40 units. Would you do one flood determination for the entire building or one for each condo unit in the building? Typically when the Bank does loans with multiple properties used for collateral, the Bank obtains separate flood determinations for each property. What would you do?
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Flood Compliance
#2264659 - 01/12/22 04:17 PM Re: 40 Flood determinations or one? JacksTigger
rlcarey Online
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rlcarey
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Galveston, TX
They all have the same address do they not? They are all in one building are they not? If the answer to those questions is yes, then it comes down to your contract with your FHD vendor.
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#2264661 - 01/12/22 04:20 PM Re: 40 Flood determinations or one? JacksTigger
JacksTigger Offline
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JacksTigger
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lost in compliance land
sorry what is FHD?
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#2264663 - 01/12/22 04:21 PM Re: 40 Flood determinations or one? JacksTigger
rlcarey Online
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Galveston, TX
Flood Hazard Determination vendor.
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#2264664 - 01/12/22 05:00 PM Re: 40 Flood determinations or one? JacksTigger
KwC Offline
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We had a similar situation recently. The borrower collateralized 35 out of the 40 units in the condo building. We ordered only 1 flood determination, and add the unit numbers on the comment section. No way we are ordering 35 flood determinations.

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#2264681 - 01/12/22 07:39 PM Re: 40 Flood determinations or one? JacksTigger
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JacksTigger
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lost in compliance land
Thanks that's what we were thinking but wanted to make sure we didn't miss something.
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#2266693 - 02/22/22 07:23 PM Re: 40 Flood determinations or one? JacksTigger
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Do you understand the opinion here by Wolters Kluwer to be inaccurate?

https://www.settlementservices.com/FDS_Web/Content/How_many_determinations.pdf

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#2266696 - 02/22/22 07:33 PM Re: 40 Flood determinations or one? JacksTigger
rlcarey Online
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rlcarey
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An 8 year old opinion? When that was issued, the instructions on the reverse side of the FHD included the following.

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.

This is what it says now:


MULTIPLE BUILDINGS: For guidance regarding multiple buildings, please contact your regulator, servicer, lender or other entity as applicable.
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#2266720 - 02/22/22 09:37 PM Re: 40 Flood determinations or one? JacksTigger
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Yeah, I feel you. It's never really been specifically addressed by a Regulator, as far as I am aware. Logically, if they are all in the same building, one should work.

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