Answer:
Yes to all 3 questions.
The building has value. You may have chosen not to consider it for LTV purposes but that does not negate the building having value. You need to review the section in the Mandatory Purchase of Flood Insurance guidelines discussing low value buildings on high value land.
The building is being used as a dwelling so under what exemption in Reg C would you propose it being exempt?
First published on BankersOnline.com 8/6/12