The existing Flood Q&As say that you needed to investigate discrepancies only if the risk-zone ratings are different.
"71. What should a lender do when there is a discrepancy between the flood hazard zone designation on
the flood determination form and the flood insurance policy?
[Answer:] A lender should only be concerned about a discrepancy on the Standard Flood Hazard
Determination Form (the SFHDF) and the one on the flood insurance policy if the discrepancy is between
a high-risk zone (A or V) and a low- or moderate-risk zone (B, C, D, or X). In other words, a lender need
not be concerned about subcategory differences between flood zones on these two documents."
That said, the proposed (not final) Q&As now say this:
"ZONE 2. Is a lender in violation of the Regulation if there is discrepancy between the flood zone on the SFHDF and the flood insurance policy declarations page?
No, a lender is not in violation of the Regulation if there is a discrepancy between the flood zone on the SFHDF and the flood zone on the policy declarations page. As provided in Q&A Zone 1, a lender should consider documenting any zone discrepancy in the loan file."
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com