If we are renewing a loan where the property is in a special flood zone and we have a notice to customer of this in file, are we required to give them a new notice at or prior to renewal when a new flood determination was not ordered?
Thanks!

A loan renewal is a triggering event under the flood insurance rules and would require a new notice. Below is a link to a 2001 FDIC FIL that is a summary of the rules. Look for Notices to Borrowers (12 C.F.R. § 339.9)

http://www.fdic.gov/news/news/financial/2001/fil0181a.html

The FDIC will write you up for this even though the original notice to the borrower AND the current flood insurance policy is in the file. There is no common sense in the flood regulation.

Boy did you say a mouthful waldensouth! Is there much common sense tho in any reg?!?!?