1. I know the FDIC is monitoring zone compliance, or at least in my area they are. I can't speak with certainty but it is my opinion if you have a pattern of unreconciled zone differences it would subject you to CMPs. At a seminar I attended on the 13th the speaker made it clear that if the zone is inaccurate on the policy they will not pay a claim, however he did say that the insured had 30 days to pay the difference in premiums. So, if the zones are not legitimate at closing then you are closing the loan without adequate insurance coverage and are in violation of the Law. (Just my opinion)
2. If insuring through the NFIP each building located in a SFHA must be insured by its own NFIP policy.
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The opinions expressed are mine and they are not to be taken as legal advice.