The point is that there is no requirement to pull a flood determination on vacant land. So, there should not be a question. You are under no obligation to inform the borrower about anything. Basically, it is a waste of your client's money at this point in time.
Let alone, you are most likely providing them a notice that is telling them something that is not true:
We are giving you this notice to inform you that:
The building or mobile home securing the loan for which you have applied is or will be located in an area with special flood hazards.
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