We have a construction loan to a builder that is to be secured by six properties that are showing as in a SFHA. The customer has provided a Conditional Letter of Map Amendment (CLOMA) from FEMA. The CLOMA states that once the properties are completed and an as-built elevation certificate is provided, the properties will be designated as in Flood Zone X. Does the CLOMA relieve of us of the obligation to require flood insurance during construction, or since it is conditional on the final elevation certificates, do we need to require flood insurance until the CLOMA can be finalized? My guess is the latter.

Just found my answer here: https://hazards.fema.gov/onlinelomc/ext/Help/loadFaq

The CLOMA does not remove the obligation to require flood insurance.