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Flood Determination for Property w/o Building

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Question: 
Loan secured by real estate (3 acres), block building/house on property, tenant lives in block house, house is insurable, value of house is -0-. LTV based on value of land only. Even though property has building on it, we are not considering the building as part of collateral or in valuation of collateral. Q. Is flood determination still required? Q. Is HMDA date sheet required? Q. Is Government Monitoring info still required?
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

First published on 08/06/2012

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