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#2175478 - 04/26/18 09:41 PM Office Bulding in apartment complex, NFIP?
Just Confucius Offline
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Joined: Mar 2011
Posts: 5
I have a loan with an apartment complex on one tract. 1 Determination pulled for the entire complex. 15 buildings (232 units total) plus the office. We have flood policies for all 15 buildings at $250,000 as well as the office building. My question, shouldn't the office building have an NFIP max of $500,000? Technically it's a non-residential property.

Thoughts?

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Flood Compliance
#2175491 - 04/26/18 10:41 PM Re: Office Bulding in apartment complex, NFIP? Just Confucius
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,356
Galveston, TX
Yes and considering the other 14 units are more than 4 family buildings - they need to go to $500,000 also depending on the loan amount and actual cost values.
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#2175568 - 04/27/18 02:40 PM Re: Office Bulding in apartment complex, NFIP? Just Confucius
Just Confucius Offline
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Joined: Mar 2011
Posts: 5
Thank you for the response. Follow up questions

- With regards to the flood determination pulled for the Apartment Complex, I've read conflicting information that determinations should have been pulled for each building (Bldg 1-15, plus the office/clubhouse)....or at the very least the building numbers should have been indicated on the one determination page below the collateral address. Thoughts?

-With regards to the NFIP max on the buildings, I was just informed that the borrower also maintains private flood insurance on top of the $250,000 NFIP coverage. Based on the information I was given, the deductible for the private insurance is $250,000 per building which is to cover the deductibles of the NFIP coverage limits. I've never encountered a situation like this before, is this a practice that can be used? I'm not too sure how to proceed in this case. Any help will be appreciated.

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#2175585 - 04/27/18 03:26 PM Re: Office Bulding in apartment complex, NFIP? Just Confucius
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,356
Galveston, TX
The current instructions on the SFHDF read: MULTIPLE BUILDINGS: For guidance regarding multiple buildings, please contact your regulator, servicer, lender or other entity as applicable.

Previous versions read: MULTIPLE BUILDINGS: If the loan collateral includes more than one building, a schedule for the additional buildings/mobile homes indicating the determination for each may be attached. Otherwise, a separate form must be completed for each building or mobile home. Any attachments should be noted in the comment section. A separate flood insurance policy is required for each building or mobile home.

I am not aware of any specific guidance from the individual regulators on this issue.

Not unusual for a private umbrella policy to be in place if the value of the structures support it. You still have to consider the maximum available insurance for the apartment buildings is $500,000 in your calculations and if need to make your minimum flood insurance number that the private policy is acceptable to the bank..
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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