When a loan is "refinanced" not "renewed" am I ok to use the previous determination form as long as the three conditions are met: the previous determination was documented on a SFHDF, the determination is less than 7 years old, and no map revisions or updates have taken place?

We are conducting a review on real estate loans, and this question has come up. One person is concerned that because the term "renewed" is used, we cannot use the previous determination.

Thanks for your help in clearing up this issue.

A Q & A published for comment by the FFIEC in the 7/23/97 Federal Register answered your question this way: "If a subsequent loan involving a refinancing or assumption is made on the same property by the same lender who obtained the original determination, and the other requirements contain in Section 528 are met, the lender may rely on the previous determination."

We get Life of Loan monitoring on all flood determinations that we order. That way, as long as we don't receive a notice from our vendor that the flood determination has changed, then we rely on the original verification. At this point, we do not have any verifications that are more than 7 years old.

Yes, you can use the existing flood determination BUT you should check your agreement with the flood vendor to find out whether you will continue to have life of loan coverage if the loan is rewritten. This is one of those times when you need to check the fine print in the contract with the vendor. Also look at the process that you and the vendor use for tracking loans. If you change the loan number, you may have to start over with the flood cert simply for tracking purposes.