We have two loans using the same property as collateral and the flood determination used for the first loan indicated the property was in the flood hazard area. Correct procedures were followed and we've maintained flood coverage. When the 2nd loan came along the flood determination indicated that the property was not in a hazard area and no one recognized the discrepancy. Same vendor used for both determinations. We called the vendor and they've amended the 2nd determination to now indicate the property is in the hazard area. I don't have a problem with the amount of coverage I have, but I do have a question about the Notice to Borrower. Should I send this out to have it signed by the borrower and they should date it current date? Is there anything else that I'm overlooking?

I would want certification of which determination is the correct one and you, the financial institution, are responsible for the accuracy regardless of it being obtained from a 3rd party.

If the property is indeed in the SFHA you have a violation for not providing the notice. You should provide the notice now but keep in mind that doesn't cure the violation. If you are fined for the violation then you may want to look to the vendors warranties in the contract.

Thank you Dan. Will check into it further by looking at the map ourselves.