Is there really a risk to having a flood zone discrepancy like AO versus AH when they are listed at the same rate on the FEMA Rate Tables? I'm talking a discrepancy between the insurance and the SFHD.

Thanks!

I asked this exsct question of Rich Slevin of the NFIP at a workshop he conducted last week. He advised that we did not need to be concerned about the "secondary" letter or number. He stated that, as far as we need to be concerned, "A1" is the same as "A30" and the same as "AE". He indicated that as long as the initial letter is the same (e.g., "A", "V", "B", etc.), that is all we need to be concerned about.

I'm not questioning Mr. Slevin - I agree that A1-A30 is equivalent to AE. FEMA posts this in their zone classifications. However, AE is NOT the same as AO, AH, etc. While I don't see as much criticism of this, it is not correct. Would Mr. Slevin agree that it's okay to have AO on the SFHDF, but AE on the policy?

Yes, that was my question. As an OCC-regulated lender, there seems to be an expectation that we should compare the flood zone listed on the determination to the flood zone noted on the insurance policy to ensure they match. So at the workshop, I asked how exact the match had to be--for example, did we need to address it when the determination says "A1" but the policy says "A30." His response was that A1-30 and AE were basically the same for these purposes, and that we did not need to view that as a discrepancy. I don't think he was saying that these zones are exactly the same, but I thought he was saying that, as a lender, if we saw this type of discrepancy between the determination and the policy, the rate was not impacted, and it would have no effect on their coverage, so we didn't need to treat this as a discrepancy that needed to be corrected.

David, if this doesn't seem correct to you, I will be happy to e-mail him and ask the question again to make sure he understood my question and that I correctly understood his answer. This is an issue that is a hot topic in our bank right now, and I need to make sure I have the correct understanding. I felt that I had that after I asked the question of Mr. Slevin, but if you feel differently, then I definitely want to try to clear it up. Thanks.

I agree 100% with this statement. It's a fact. My question is would he say AO is the same as AH? They aren't. I wonder if he was saying AO is close enough to AH or was he specifically addressing the A1 through A30 is the same as AE (that's a different issue).

It would be great to get his opinion on other discrepancies.

I asked the question in a general sense, and he responded as I indicated. So we did not discuss AH vs. AO, etc, or anything else more specific.

I will e-mail him and follow up with the question, being more specific with the flood zones beyond A1-A30 and AE, to see if he feels the answer is different if those zones are involved. I will let him know we are discussing this in this forum and need clarification. Thanks.