Back in 2008, FEMA issued a letter that outlined procedures relating to flood zone discrepancies. Bank's often times would encounter their SFHDF zone would not match the flood zone on the insurance declaration sheet. The letter stated that WYO companies and the NFIP Servicing Agents were directed to use the most hazardous flood zone for rating when presented with two different flood zones. I often had to send a copy of the letter to insurance agents to get them to change the zone. I called NFIP and they could not tell me if this letter is still valid. Years ago certain agency regulators looked at this during exams and others agency regulator did not when looking at flood compliance.

Should we still make sure the zones match up?

No. FEMA 2.0 changed the risk rating process and you no longer need to match the flood zone on the declaration page to the zone on the determination. This is backed by the proposed flood FAQs.

Here is a(n embarrassing Halloween ) video where I explain the change with FEMO 2.0 in more detail than I have time to do today: https://www.compliancecohort.com/blog/video-no-flood-zone-on-declaration-page

Thank you Adam!

Great clip Adam - you are definitely a man of many talents.

Adam Witmer, one final question. After watching your clip it it sounds like Private Policies will still have a flood zone on the dec sheet. If it is a private policy, should we make sure the SFHDF and dec sheet zones match?

Not Adam, but private insurance companies normally care less about a flood hazard rating that is determined by FEMA. There would be no such requirement on a private policy.

Thank you!

You should consider documenting the loan file... if you want to.