This may be a picky question, but is the lender ID number on the Standard Flood hazard Determination Form crucial? My "yellow book" says it's not optional. Has anyone had any mention of this on an exam?

The examiners were more concerned about us having the determination form and flood insurance in place, but I am positive that they will be sure to monitor the completeness of the form the next time around. The SFHD form instructions also say that that the lender funding the loan should identify itself. They did not specify that this was an optional field.

We hire consultants to do some auditing for us. In a recent review they wrote us up for that exact issue. They stated that the lender ID is required information and we are responsible for the form's proper completion even if we don't prepare it. They informed us that FDIC has cited some banks on this matter.

During 2001, Flood seemed to be a hot topic with the FDIC. They will definitely write you up for failure to include a required field such as the Lender ID number. When we switched from faxing in our requests to our flood provider to the internet version, several of our banks forgot to include their lender ID and none of their forms contained it. Definitely noticed and mentioned during next exam.

In my experience as a consultant - many of our banks have been told to complete the Lender ID (or complete it correctly - it is NOT the bank's TIN. It is the FDIC Certicate # - or CALL Report #) but few have been cited for this. More likely, they were cited for other SFHDF completion problems and this was added. Our firm is also telling banks to be sure to complete this field and correctly.

Ditto to what David said -- except I have seen write-ups for only the bank's information missing. All of the agencies are being very strict about this. I have seen several OCC write-ups on this and also one Federal Reserve report. Those numbers have to be in there. It is to make sure that the loan is properly tracked.

For a thrift bank would the lender# mean our thrift number?

The instructions state:
The lender funding the loan should identify itself as follows: FDIC-insured lenders should indicate their FDIC Insurance Certificate Number (CALL Report Number); Federally-insured credit unions should indicate their charger/insurance number; Farm Credit institutions should indicate their UNINUM number. Other lenders who fund loans sold to or securitized by FNMA or FHLMC should enter the FNMA or FHLMC seller/service number.