Our lender has notified our borrower that the property securing a loan is in a SFHA by way of emailing copies of the SFHDF. The email also advises the borrower that we don't require insurance levels above the federal minimums. Our lender maintains that this adheres to all stipulations within FEMA guidelines (except for the lack of an explanation of the eligibility requirements to receive disaster relief), which provides for alternative means of communication when notifying a borrower of flood insurance requirements.
I maintain that the alternative method of notice is not applicable in this circumstance. It applies if the bank obtains written assurance that a seller or lessor has provided notice to the purchaser or lessee, and does not allow that the bank can solely provide the SFHDF, with an explanation that it doesn't require insurance above the minimum.
Who's right??