Frequently Asked Questions

As with all federal regulations, maintaining compliance begins with understanding them.

Understanding the mandatory purchase of flood insurance requirements and the flood insurance guidelines is no simple task. In the nearly three decades that we've been in business, you could say that we've just about heard it all. With all of our experience and expertise, we have the resources to give you the answer to pretty much any flood compliance question that comes your way.

On this page you'll find a collection of responses to the most frequently asked questions about both regulations and our policies and procedures. Hopefully, we can impart a bit of the knowledge that we've gained through our many years of flood experience. As this resource is for informational purposes only, we encourage you to seek guidance and direction from your legal department or from the Regulatory Agency itself prior to making any decisions related to policy or practice. If you read anything that triggers another question that you don't see here or if you have any suggestions, please email us at




The National Flood Insurance Program (NFIP) defines a flood as "a general and temporary condition of partial or complete inundation of normally dry land areas (at least 2 or more acres or 2 or more adjacent properties) from overflow of inland or tidal waters or from the unusual and rapid accumulation or runoff of surface waters from any source."

Available in participating communities through the National Flood Insurance Program, federal flood insurance provides monetary protection against direct physical loss by or from a flood to an insured property. Furthermore, as a means of recovering from the aftereffects of flooding, it is a more dependable alternative to federal disaster assistance, which is only available during a Presidentially declared disaster and must be repaid as an interest-bearing loan. Flood insurance can be purchased to cover structural damage only, structural damage and personal property damage, or for renters it can be purchased to cover personal property only.

Standard homeowner's insurance does not cover property damage caused by a flood.

Prior to flood insurance being offered through the National Flood Insurance Program in 1968, federal disaster relief was the only financial assistance provided to flood victims as the private insurance industry did not offer flood damage coverage. The monetary drain on the U.S. Department of the Treasury and taxpayers from repeated flood disasters led to this federal intervention.

The cycle of flooding followed by federal disaster assistance continued as the federal government learned that property owners were not voluntarily purchasing flood insurance. To further shift financial responsibility from taxpayers to policyholders, the federal government first mandated flood insurance coverage for properties in designated flood hazard areas in 1973 by requiring federally regulated banks, mortgage companies, loan servicers and other lending institutions to make flood insurance coverage a condition of the loan.

Federally regulated banks, mortgage companies, loan servicers and other lending institutions cannot make, extend, renew or increase a loan on improved real estate located or to be located within a Special Flood Hazard Area in a community that participates in the National Flood Insurance Program unless the improved real estate or personal property securing the loan has flood insurance coverage for the life of the loan.

For loans secured by improved real estate located in a Special Flood Hazard Area, lending institutions must require flood insurance in an amount at least equal to the outstanding principal balance of the loan up to the maximum limit of coverage available. Flood insurance coverage is limited to the value of the building; therefore, when calculating the minimum coverage, the lender should exclude the value of the land.

The National Flood Insurance Act of 1968 authorized the creation of the National Flood Insurance Program (NFIP). This made federally subsidized flood insurance available to property owners residing in communities that agreed to participate in the NFIP through the adoption of floodplain management guidelines.

The Flood Disaster Protection Act of 1973 mandated that federally regulated flood insurance be required as a condition of loans extended on improved real estate located within the designated Special Flood Hazard Area.

The National Flood Insurance Reform Act of 1994 (the "Reform Act") significantly strengthened the mandatory purchase requirement by instituting regulatory fines against lending institutions that failed to comply. It also required, in certain conditions, the escrow of flood insurance premiums and the lender-placement of flood insurance, and it developed a standard form and criteria for documenting lending institutions' compliance.

The Flood Insurance Reform Act of 2004 instituted requirements for additional agent training for insurance agents selling flood insurance, required FEMA to disseminate more informational material to policyholders, and attempted to mitigate the impact of repetitive loss properties on NFIP total claims by creating the Severe Repetitive Loss Pilot Program.

The 1994 Reform Act required that banking regulators issue and enforce the flood insurance regulations for the lending institutions subject to their jurisdiction. The regulators monitor compliance through examinations and assess civil penalties as applicable. The Federal Regulators have issued a "Questions and Answers" document which provides additional regulatory guidance to lending institutions and may also be involved with FEMA from time to time in revisions to the guidelines through releases in the Federal Register.

The banking regulators are the Federal Reserve Board, the Office of the Comptroller of Currency, the Office of Thrift Supervision, the Federal Deposit Insurance Corporation, the National Credit Union Association and the Farm Credit Administration.

Violations under the federal regulations include making, increasing, renewing, or extending a loan on improved real estate in the Special Flood Hazard Area without (1) Placing flood insurance in the appropriate amount, (2) Escrowing premiums for flood insurance, when applicable, (3) Providing required notices to borrower, (4) Lender-placing flood insurance, when applicable, and (5) Providing notice of servicer and change of servicer, as applicable.

A regulated lending institution that is found to have a pattern or practice of committing violations shall be assessed a civil penalty of $385 per violation up to an aggregate annual amount of $125,000 against an institution. The per violation and aggregate amounts of civil penalties are adjusted by statute for inflation on a periodic basis. Additional actions that can be taken against an institution include unsatisfactory bank ratings and cease and desist orders in extreme cases.

Government-Sponsored Enterprises, including Fannie Mae and Freddie Mac, are required to implement procedures to ensure that flood insurance is obtained and maintained on designated loans. Fannie Mae and Freddie Mac accomplish this through the agreements they enter into with the lending institutions that sell loans to them. As a condition of Fannie Mae and Freddie Mac's agreement to purchase loans from a lending institution, the lender must adhere to the mandatory purchase of flood insurance regulations.

Because Fannie Mae and Freddie Mac are privately owned corporations, they can protect themselves by establishing loan purchase guidelines that are more stringent than the federal regulations. For example, for a single family residence, Fannie Mae and Freddie Mac require that flood insurance be maintained in an amount at least equal to the lowest of the unpaid principle balance of the loan, the maximum amount of insurance available from the NFIP or the replacement cost of the insurable improvements. When the unpaid principle balance is the lowest option, it must be at least 80% of the structure replacement cost. However, if the unpaid principle balance is less than 80% of the replacement cost, the required insurance coverage amount must be at least 80% of the structure value.

Another special requirement to note is that while the regulations do not prohibit the making, extending, increasing, or renewing of loans on properties in the Special Flood Hazard Area located in non-participating communities, Fannie Mae and Freddie Mac will not purchase them.

Lending institutions that sell loans to the secondary market should familiarize themselves with the details of these guidelines which can be found at:



For over twenty years, the Federal Emergency Management Agency's (FEMA's) mission has been to lead America to prepare for, prevent, respond to and recover from disasters. In 1979, through an executive order of President Carter, FEMA was created as a separate federal agency responsible for coordinating national hazard mitigation and recovery efforts. In March 2003 FEMA became part of the newly formed Department of Homeland Security under the Office of Emergency Preparedness and Response.

Today, FEMA manages the National Flood Insurance Program and the U.S. Fire Administration. FEMA continues to lead the effort to prepare the nation for all hazards and effectively manage federal response and recovery efforts following any national incident. It also initiates proactive mitigation activities and trains first responders.

The National Flood Insurance Program (NFIP) is managed by FEMA and contains three components: flood insurance, floodplain management and flood hazard mapping. Participation in the NFIP is determined by whether the community adopts and enforces floodplain management ordinances in exchange for the protection of federal flood insurance availability to its citizens. Over 20,000 participating communities across the United States voluntarily participate in the NFIP.

Congress authorized the NFIP in 1968 as part of the National Flood Insurance Act, making federal flood insurance available to property owners for the first time. Prior to moving under the sponsorship of FEMA in 1979 (which is now part of the Department of Homeland Security), the NFIP was part of the Department of Housing and Urban Development.

In the Emergency Program FEMA provides a limited amount of flood insurance for the community's citizens at less than actuarial rates in return for an agreement of basic floodplain management to control development.

Communities in the Emergency Program either do not have a flood map that identifies its flood hazard areas or it has a Flood Hazard Boundary Map (FHBM) that approximates the flood hazard areas (because it is not based on a detailed flood study.) For communities that participate in the Emergency Program, flood insurance coverage is limited to $35,000 for a residential building and $10,000 for residential contents. Approximately one percent of the participating communities are in the Emergency Program.

A community that joins the Regular Program is usually provided with a detailed Flood Insurance Study based on an engineering analysis and a Flood Insurance Rate Map (FIRM) that delineates the Special Flood Hazard Areas. In return, the community adopts a more comprehensive floodplain management ordinance, which more fully controls development. In the Regular Program, flood insurance coverage is currently available up to $250,000 for a residential building and $100,000 for residential contents.

Although participation in the NFIP is voluntary, properties located in non-participating communities are not eligible for flood insurance through the NFIP and federal disaster assistance is limited.

In the event of a flood disaster, federal disaster assistance is not available for repair or reconstruction of buildings located in the Special Flood Hazard Area (SFHA). Federally backed loans, such as those made through the Federal Housing Administration, the Department of Veteran's Affairs, or the Small Business Administration, cannot be made for acquisition or construction of improved real estate located in the SFHA. However, conventional loans can be made, even on properties in the SFHA.

Even though flood insurance is not available, lending institutions are still required to determine if the improved real estate is within the SFHA. Lending institutions must consider the risks of making loans on these properties given that flood protection is limited. Flood insurance might be available through private insurance companies outside of the NFIP, but at a much higher premium.

When a participating community acquires (through annexation or otherwise) an area from a non-participating community, flood insurance becomes available on properties within the newly acquired area. In order to purchase flood insurance, citizens may need to provide documentation stating that the annexing community has jurisdiction over and administers floodplain ordinances over the annexed area. When a non-participating community acquires an area from a participating community, no new flood insurance policies can be written on properties within the annexed area and existing policies cannot be renewed upon expiration unless and until the non-participating community joins the program.

By participating in the National Flood Insurance Program, communities agree to adopt and enforce floodplain regulations governing construction and development in and around Special Flood Hazard Areas. In return, the federal government makes flood insurance and federal disaster assistance available to the community and its residents. FEMA works with communities to help them comply with this agreement; however, if the community fails to comply and does not correct its actions even after a 90-day written notice, then the community is placed on probation.

The probationary period continues for at least one year, and during that timeframe, a $50 surcharge is added to insurance policies as they are issued or renewed within that community. The purpose of probation is to focus the community's efforts on corrective action so as to avoid suspension.

If a community fails to correct its non-compliant actions, then that community is given 30 days to demonstrate to FEMA why it should not be suspended from the program. If suspended, it becomes a non-participating community, and no new policies can be issued nor can they be renewed. Policies in force at the time of the suspension remain in force until the coverage period expires.



The lending institution must determine or have a third party determine if a building or mobile home (and personal property securing the loan, if applicable) is located within a Special Flood Hazard Area (SFHA) as shown on the effective Flood Insurance Rate Map for the property's community. If any portion of the improvements is located within the SFHA, then flood insurance is required.

The steps, as outlined by FEMA, to make the flood zone determination are as follows: (1) Find the correct flood map, (2) Find the general location of the subject property, (3) Find the specific location of the subject property's improvements on the flood map, and (4) Identify the flood insurance risk zone as shown on the flood map.

Learn more about reading a Flood Insurance Rate Map.

A flood zone determination must be made or obtained whenever a federally regulated lender makes, extends, increases or renews a loan secured by a building or mobile home. In addition, federal regulators recommend that lenders and servicers, as a matter of safety and soundness, conduct periodic reviews of existing portfolios and perform prospective analyses on portfolio acquisitions, as well as monitor changes triggered by flood map revisions.

Yes, the Standard Flood Hazard Determination Form (SFHDF) is a required federal document that federally regulated lending institutions must complete or have completed as a condition of making, extending, increasing, or renewing a loan that is to be secured by improved real estate.

Loans that are exempt from the mandatory purchase requirements, including the requirement for a flood zone determination, are on state-owned property covered by self-insurance acceptable to the director of FEMA and on loans with an original outstanding balance of $5,000 or less and a repayment term of one year or less.

Yes, the mandatory purchase requirements, including the requirement for a flood determination, apply equally to commercial properties as they do to residential properties. In addition, the requirements apply to condominium, cooperative, timeshare units and all forms of single or multi-family dwellings.

Lending institutions have the following obligations: (1) Determine whether the building is or will be located in an SFHA; (2) Document the flood hazard determination; (3) Require that flood insurance (when it is required) is obtained to the appropriate limit; and (4) Ensure that required flood insurance is maintained for the term of the loan or added if the property is subsequently determined to be in an SFHA.

There is no requirement for the lending institution to provide a copy of the Standard Flood Hazard Determination Form to the borrower, regardless of whether or not the property is within the SFHA. However, the lending institution must keep a record (hardcopy or electronic) of the flood determination or be able to retrieve a copy of the form in the event that a regulator requires it.

The regulations do not prescribe a specific timeframe prior to a loan closing; however, if the property is in the SFHA, then within a reasonable time period prior to the loan closing, the lending institution must provide a notice to the borrower stating that flood insurance is required. Some regulators agree that a "reasonable period of time" is at least 10 days.

Lending institutions may make their own flood determinations; however, most choose to use a third-party provider because of the resources and expertise required to make the determinations and the guarantees provided by these companies. For a lender to use a flood determination made by a third-party provider, the determination must be "guaranteed" according to the regulations. Lenders should ensure that the company is following FEMA guidelines with respect to its flood determinations. Whether or not a lending institution utilizes a third party provider, the ultimate, non-delegable obligation to require flood insurance on designated loans is on the lending institution.

As a CoreLogic client, you are in the unique position of receiving certifications that are validated through the instantaneous comparison of two completely separate databases of determinations. Each one of our databases was developed by separate teams of technology and operations experts, with each team using a different research methodology. When it comes to accuracy, the melding of these two alternate databases is vastly superior to either alone.

The foundation database is compiled of manually completed determinations. These are determinations that a trained research analyst have completed based on a review of the flood map from FEMA. The researcher may also use other resources from our extensive library, such as tax maps, plats, surveys, subdivision maps, lot and block information, section/township/range, aerial imagery and legal descriptions, to accurately locate the property and structure on the FEMA map.

The second database is compiled using state-of-the-art GIS (Geographic Information Systems) technology, which combines digitized flood maps with street, parcel and address information.

If you've never seen a flood map, it may surprise you (the dark grey shaded areas are the high risk flood zones). You'd think that a map would make it easy to find your way around, but a flood map may be different. Though FEMA’s mapping initiatives have made efforts to improve the flood maps, many times there aren't many streets or landmarks you can use to locate your property. That's why it takes expertise and plenty of resources, and we have both, to consistently render accurate determinations.

Specific guarantees are prescribed by the service agreement or contract between CoreLogic and its client and may vary according to the particular product. If you have questions related to the guarantees under your contract, please contact your account manager or account coordinator.

Generally speaking, if CoreLogic incorrectly states that a building is not in the SFHA on the effective Flood Insurance Rate Map and the building suffers flood damage, then CoreLogic will reimburse the client for the structural damage caused by flood as if a valid NFIP flood insurance policy were in effect at the time of the loss.

Conversely, if CoreLogic incorrectly states that a building is in the SFHA on the effective Flood Insurance Rate Map and a flood insurance policy is required based on this flood determination, then CoreLogic will reimburse the client up to the amount of the flood insurance policy premiums paid which are not reimbursed by the insurance company.

A lender may only rely on a previous flood determination when increasing, extending, renewing or purchasing a loan, not when a lender originates or makes a loan. The previous determination must have been completed within seven years on the same property and recorded on the Standard Flood Hazard Determination Form. Furthermore, the lender must confirm that no map revisions or updates since the original determination have placed the property into the Special Flood Hazard Area or affected the area of the property.

The mandatory purchase of flood insurance decision must be based on the current Flood Insurance Rate Map for the property's community. The effective flood map supersedes a flood determination based upon a previous, outdated flood map. There is no "grandfathering" of the mandatory purchase requirement; however, a flood insurance policy may be rated on the prior flood map under certain conditions based upon the Grandfather Rules of the NFIP.

Property owners may qualify for the 2-year PRP extension, which was made available January 1, 2011. In order to qualify, the property must be newly mapped into the SFHA based on a map revision and must also meet the PRP loss history requirements. Qualifying properties will fall into one of the following areas:

  • Properties newly mapped into an SFHA on or after October 1, 2008 and before January 1, 2011 may be eligible for 2 policy years between January 1, 2011 and December 31, 2012.
  • Properties newly mapped into an SFHA on or after January 1, 2011 may be eligible for 2 policy years following the effective date of the map revision.

FEMA released a memo which provides additional information about the NFIP’s PRP extension program.

It is not uncommon for other parties, such as borrowers, surveyors, community officials, realtors, insurance agents, builders, or appraisers to have differing opinions about a property's flood zone designation. This can occur for a variety of reasons: (1) Reliance on information other than the Flood Insurance Rate Map, (2) Historical information that differs from the flood map, (3) Updated information not reflected on the flood map, (4) Different interpretations of the flood map, or (5) A resistance to paying for the required flood insurance.

When a dispute over a flood zone determination occurs, a discussion of the methodology used and a review of the flood map can often resolve the situation. A CoreLogic representative can assist with this review, and in most situations, is able to resolve the dispute. If, after the review, the borrower still believes that the flood map has not been interpreted correctly, then the borrower, jointly with the lender, can request a Letter of Determination Reviewthrough FEMA.

The Letter of Determination Review is a process through which FEMA will determine if the Standard Flood Hazard Determination Form (SFHDF) that includes the flood zone determination used by the lender is accurate. For example, if a lender is requiring flood insurance based upon a flood zone determination that states that the subject property is in the Special Flood Hazard Area (SFHA,) then FEMA will confirm whether or not the property is indeed in the SFHA based upon the Flood Insurance Rate Map (FIRM.)

FEMA requires the following items for this process: (1) A letter signed by both the borrower and lender requesting the review, (2) A copy of the lender's SFHDF, (3) A copy of the dated Notice to Borrower document, (4) A copy of the applicable FIRM, (5) All documents used by the lender to complete the flood zone determination, and (6) A check or money order in the amount of $80.00 made payable to the NFIP. This request must be submitted within 45 days of the Notice to Borrower document.

Differing interpretations of the flood map may occur from time-to-time, especially in areas where the flood map does not include details or for properties near the edge of the Special Flood Hazard Area. The specific location of the building is fundamental to the flood zone determination; thus, a few feet difference in a building's location can result in a different conclusion on the Standard Flood Hazard Determination Form.

When a discrepancy in flood zone determinations occurs between flood determination providers, the lending institution can request that the companies review their work, which hopefully leads to a consensus. In some cases, the vendors may be able to provide a flood map exhibit showing how they reached their conclusion. If the matter cannot be resolved, then the borrower and lender may elect to pursue a Letter of Determination Review, if appropriate.

The Standard Flood Hazard Determination Form asks the following question: "Is the Building/Mobile Home in Special Flood Hazard Area (Zones containing the letters ‘A' or ‘V')? " Thus, the mandatory purchase of flood insurance requirement is tied to the location of the improvements (building/mobile home) on the property and not the land itself. If no portion of the building itself (including decks and screened porches) is located within the Special Flood Hazard Area on the flood map, then the federal flood insurance requirement does not apply.

When a lending institution makes, increases, renews, or extends a loan, and it is determined that the building securing the loan is located or to be located in the Special Flood Hazard Area (SFHA), then within a reasonable period of time before the loan closing, the lender is to provide a written notice to the borrower informing him or her of the special flood hazards. The written notice must contain the following: (1) A warning that the building is within an SFHA, (2) A description of the mandatory purchase of flood insurance requirements, (3) A statement as to whether flood insurance may be purchased through the NFIP or through a private insurer, and (4) A statement as to whether federal disaster relief is available in the community, as well as other relevant flood insurance information.

The regulations require that lenders be able to retrieve documentation evidencing the borrower's receipt of the Notice. Lenders may use the sample form of the Notice and are considered to be in compliance if they do; however, although the regulations do not require the use of the sample form, lenders must ensure that the version they use contains the fourfold regulatory requirement listed above.



FEMA works with states, communities and the private sector to produce flood maps for communities throughout the United States and its territories. Over 100,000 map panels produced by FEMA provide valuable information for community officials, developers, insurance personnel, surveyors, lending institutions, real estate agents, engineers and private citizens.

Flood maps are used to guide and control development, determine potential risk of flooding, aid in floodplain management, determine a loan's flood insurance requirement, and determine the proper flood insurance rate.

Used in FEMA's Emergency Program, an FHBM is provided by FEMA and based on approximate data that reflects a general representation of the community's Special Flood Hazard Areas. When a community converts from FEMA's Emergency Program to its Regular Program, FEMA provides the community with a FIRM. Typically, this map is based on a Flood Insurance Study (FIS), which is a detailed floodplain assessment. The FIRM includes the floodplain's Base Flood Elevations (BFEs) and the delineation of the regulatory floodway. This detailed information is used to direct floodplain management and rate flood insurance based upon the actuarial computation of the risk.

An SFHA, otherwise known as the one-percent-annual-chance floodplain, is commonly referred to as the "100-year floodplain." However, FEMA and its communities are moving away from this reference because it can easily be misinterpreted to mean that an area will only flood once every one hundred years. In fact, the true meaning of the term is quite the opposite: In any given year, there is actually a one percent chance or greater that an SFHA will experience flooding that equals or exceeds its boundaries. There are geographic areas that have sustained multiple "100-year" or "one-percent-annual-chance" floods within concurrent years.

On the Flood Insurance Rate Map (FIRM), the SFHA is shown as a darkly shaded area labeled as a flood zone containing the letters "A" or "V". FIRMs based upon a Flood Insurance Study may include the demarcation of the regulatory floodway within the SFHA.

The floodway is the stream channel and the adjacent land area reserved to discharge the one-percent-annual-chance flood without increasing the Base Flood Elevation by more than one foot. Beyond the limits of the regulatory floodway is the flood fringe. These two elements combined make up the SFHA or one-percent-annual-chance floodplain, which is shown on a FIRM as a darkly shaded area.

To comply with the mandatory purchase requirement and to complete the Standard Flood Hazard Determination Form, a lending institution is not required to report whether or not a property lies within a regulatory floodway; however, a lending institution is required to determine if a building is located or to be located in an SFHA.

We've compiled a list of the various flood zones, including definitions and whether or not the flood insurance requirement applies on properties located within the flood zones.

FEMA and its mapping partners (states, communities, and private companies) make every effort to produce flood maps that accurately depict the flooding risk in a given geographic area. With recent technological advances that offer improvements in precision, the accuracy has improved but can still vary depending on the technical data and the resources used to create them. Likewise, with development, population growth and flood mitigation efforts, flood hazard areas within a community change over the course of time, affecting the accuracy of the flood maps. In some communities, the effective maps date back to the 1970s, when the effort to produce flood maps for the entire country began. It is possible that these maps do not accurately reflect the current flood hazard areas for these communities.

FEMA and the federal government recognize the need for map improvements; therefore, the government has committed extensive resources to update its entire inventory of flood maps through the Map Modernization program and its current Risk MAP program.

Because there is a limit to the precision with which the flood maps can reflect every rise and fall in the terrain on a given property, FEMA allows individual property owners to submit technical data in an effort to have the flood map amended for their particular property-this is called the Letter of Map Amendment process.

FEMA’s Risk Mapping, Assessment and Planning program (Risk MAP) builds on flood hazard data and maps produced during the Flood Map Modernization (Map Mod) program.  The objectives for Risk MAP include providing communities with flood information and tools to help enhance community flood mitigation programs, which ultimately better protects home and business owners from the damaging effects of flood.

The future flood hazard area shows the locations that would be inundated by the one-percent-annual-chance floodplain based upon future hydrology conditions. This determination is based on a community's plan for development and projected growth; the future flood hazard area reflects the changes that will occur to the flood hazard area based upon that plan. A community has the choice to have the future flood hazard area appear on its flood maps. If shown, it appears as a lightly shaded area on the flood map (similar to the shaded X zone) and is labeled as "X (FUTURE)."

A Coastal Barrier Resource Area (CBRA) is a geographic area designated by Congress that is protected from development because of its rich biological habitats and geologic features. CBRAs are part of the Coastal Barrier Resource System (CBRS) and are regulated by the United States Fish & Wildlife Service which also created the CBRS maps. FEMA includes the CBRAs on its Flood Insurance Rate Maps as well for use by lenders and insurers.

Since the passage of the Coastal Barrier Resources Act of 1982, federal funds in the form of a loan, insurance payment, subsidy, grant, or guarantee are prohibited except for certain emergency situations. No federally backed loans (such as FHA loans) can be made for the purpose of constructing or purchasing improved property in a CBRA. Federal flood insurance is not available on properties that were built, or substantially improved, after the area was designated as a CBRA. Even though conventional loans can be made to purchase improved property in these areas, lending institutions should be aware that such loans would not be protected by federal flood insurance.

As for the mandatory purchase of flood insurance requirements, lending institutions are required to determine if the buildings on these properties are within the Special Flood Hazard Area (SFHA). If so, then the date of the building's construction is compared with the CBRA designation date to determine flood insurance availability. Again, if the building was constructed after the date of the CBRA designation, then federal flood insurance is not available. Flood insurance may be available outside of the NFIP.

The same requirements and restrictions apply to Otherwise Protected Areas (OPAs), which are also shown on the Flood Insurance Rate Maps. OPAs are undeveloped coastal areas used primarily for wildlife refuge or resource conservation purposes.



LOMAs are the result of an application process through which an individual property owner, or other interested party, may submit materials to FEMA that support a belief that the property should not be required to have flood insurance. If the building on a property (and the ground adjacent to the building) is at a natural elevation (not elevated by fill dirt) higher than the Base Flood Elevation, then FEMA will usually issue a LOMA, removing the property from the SFHA.

The flood insurance requirement is not waived unless or until the LOMA, which states that the building is outside of the SFHA, is issued. Until the flood map is amended by the LOMA, lending institutions are bound by the information shown on the current flood map. If a LOMA is issued, then the Standard Flood Hazard Determination Form can be updated. Once this occurs, the flood insurance requirement may be waived. Importantly, the lending institution may continue the flood insurance requirement to protect its interest. The borrower should be encouraged to consider flood insurance coverage as approximately 25 percent of all claims paid by the NFIP are on properties outside of the SFHA.

See our Flood Compliance Kit for more information on the LOMA process.

A LOMR is an official revision to a community's current flood map. It is used to change flood zones, flood elevations, mapping features, and floodplain and floodway delineations. Because a community must approve and adopt any revision to its flood map, requests for LOMRs must involve the community. This is true even if the change is to a single property that will be raised by fill dirt. In this instance, a Letter of Map Revision Based On Fill (LOMR-F), which can revise the flood map for a single property, is the appropriate procedure. Other LOMRs are much more detailed, technical, and expensive, and may even involve revising the floodplain along the entire stretch of a river through a community.

A LOMR and a LOMA have different purposes. A LOMR involves revisions to a flood map based upon changes on the ground as opposed to a LOMA, which is an amendment to a flood map because it mistakenly showed a property within the SFHA.

A property owner, or other involved party, can apply for a LOMA by completing the LOMA application and submitting the additional required documents to FEMA at the following address: FEMA NATIONAL SERVICE PROVIDER, 3601 Eisenhower Avenue, Alexandria, VA 22304-6425, Attn.: LOMA Manager. Applications are available through the FEMA Map Assistance Center (877-336-2627),, or by contacting CoreLogic's Client Services Department at (800) 447-1772.

Along with the completed application, applicants need to provide (1) A copy of the FIRM showing the location of the property, (2) An Elevation Certificate or other elevation documentation certified by a licensed surveyor or engineer, (3) A site plan or survey showing the location of the improvements on the property, and (4) A recorded deed or plat with the community's recordation stamp. FEMA takes 6-8 weeks to process applications for LOMAs provided that the required documentation is provided.

For Letters of Map Revision Based Upon Fill (LOMR-F), in addition to the above requirements, FEMA requires a processing fee in order to recover the costs associated with review and processing of the file, and a Community Acknowledgement Form to be completed by a community official. All LOMRs, including LOMR-Fs, must involve the community since changes to a given property or geographic area might affect drainage to the surrounding area. CoreLogic has additional information regarding the LOMA and the LOMR-F application processes available in the CoreLogic Flood Compliance Kit.

LOMRs and Conditional Letters of Map Revision (CLOMRs) are more detailed and technical than any other application procedure, requiring the active involvement of the community and FEMA; therefore, it is prudent that the applicant involve the community at the onset of the application. Contact FEMA with any questions regarding the required fees and documentation for a LOMR and CLOMR as they vary depending on the particular project. LOMR and CLOMR applications should be sent to FEMA.

eLOMA is a Web-based application that enables qualified users to submit simple LOMA requests to FEMA online and receive a determination in minutes in most cases. Through the use of eLOMA, licensed surveyors and professional engineers can set up an account using their individual license certification information and can obtain a determination in the time it takes to enter the required information.

eLOMA is not right for every property and situation. Currently, eLOMA is able to process requests pertaining to existing single residential structures or properties, provided no fill has been added to raise the elevation. Approximately half of the LOMAs processed annually meet the criteria for eLOMAs.

A Conditional Letter of Map Revision (CLOMR) is a formal opinion from FEMA that states whether or not a proposed project complies with floodplain management criteria and whether or not changes will be made to the existing Flood Map once the project is completed. The mandatory purchase of flood insurance requirement is based upon the current flood map; thus, a lending institution cannot waive the flood insurance requirement based upon a CLOMR.

Once the project is completed, FEMA can review the CLOMR and the finished construction; if appropriate, it will issue a final LOMR that lenders can use to waive the flood insurance requirement.



Even with the frequency of flooding events throughout the country, most lenders, servicers, and insurance personnel have heard various protests from homeowners when they are told that flood insurance is required for their home. Flooding is the most common and most costly form of natural disaster, yet people continue to feel as though it will not happen to them.

We've prepared responses to some of the most common protests. Hopefully these can help you educate your customers and overcome their concerns.

Response: According to the Federal Emergency Management Agency's (FEMA's) Flood Insurance Rate Map for your community, your house is located in a Special Flood Hazard Area (SFHA). By law, we are required to use FEMA's maps to determine the flood insurance requirement for your house. These maps not only indicate flood risk areas based on historical data, but also engineering studies to determine the likelihood of flooding in a given area.

The important thing to remember is that the SFHA is based upon a one-percent-annual-chance flood event. This means that an area might not flood for several decades or it might flood a few times in one year, depending on rainfall and drainage. Luckily, your property has not experienced a flood for quite some time; however, that is not an indicator of your future flooding probability.

If you believe that your house is not within the SFHA, then you can submit an application to FEMA for a Letter of Map Amendment. Through this process, FEMA can determine if your house should be subject to the federal flood insurance requirement. Our flood zone determination vendor, CoreLogic Flood Services, can assist us with that process. I have a document called the CoreLogic Flood Compliance Kit that can help us get started.

Response: There are several situations that could result in this scenario. Let's explore them and see if we can determine the one that applies to you.

Because the flood zone determination for flood insurance purposes is site-specific to each building, it is possible that the Flood Insurance Rate Map shows your house in a different flood zone than your neighbors' houses.

Secondly, the flood insurance requirement only applies to buildings that are secured by loans with federally regulated lending institutions; therefore, this requirement may not apply to them.

Finally, perhaps your neighbors' mortgage companies are not aware that the properties are in the Special Flood Hazard Area (SFHA.) Your neighbors should consider contacting their mortgage companies to confirm the flood zone status of their home.

Of course, if you believe that your house is not within the SFHA, then you can submit an application to FEMA for a Letter of Map Amendment. Through this process, FEMA can determine if your house should be subject to the federal flood insurance requirement. Our flood zone determination vendor, CoreLogic Flood Services, can assist us with that process. I have a document called the CoreLogic Flood Compliance Kit that can help us get started.

Response: We are not necessarily saying that the surveyor is wrong. FEMA requires that federally regulated lenders, like us, make a flood zone determination for flood insurance purposes based solely upon the current Flood Insurance Rate Map. It is possible that your surveyor is basing the flood zone determination on information other than the Flood Insurance Rate Map, such as field elevations, updated community data, or a subdivision plat. We can discuss the matter with your surveyor to try to resolve the discrepancy.

Response: We certainly understand your rationale; however, the flood zone determination for flood insurance purposes must be based upon the Flood Insurance Rate Map (FIRM.) Thus, if a portion of your house is located within the Special Flood Hazard Area (SFHA) on the flood map, then flood insurance is required.

While FEMA and your community work to make the FIRMs as useful and accurate as possible, the maps may not reflect every rise and fall in the terrain. It is possible that the map inadvertently shows your property to be within the SFHA; when, in fact, your property is sufficiently elevated to not be under a substantial risk of flooding.

If you believe that your house is not within the SFHA, then you can submit an application to FEMA for a Letter of Map Amendment. Through this process, FEMA can determine if your house should be subject to the federal flood insurance requirement. Our flood zone determination vendor, CoreLogic Flood Services, can assist us with that process. I have a document called the CoreLogic Flood Compliance Kit that can help us get started.

Response: We recognize the importance of the Elevation Certificate for your property; however, according to the official Instructions, the Elevation Certificate "does not provide a waiver of the flood insurance purchase requirement." The flood zone determination for flood insurance purposes must be based upon the Flood Insurance Rate Map. The Elevation Certificate has a threefold purpose: (1) Provide elevation information for community floodplain management, (2) Determine the proper insurance premium rate, and (3) Support a request for a Letter of Map Amendment.

If the Elevation Certificate states in Box B8. that you are in a Special Flood Hazard Area (a zone beginning with the letters "A" or "V"), but that the building is elevated above the Base Flood Elevation, then your building might be a candidate for a Letter of Map Amendment. Through this process, FEMA can determine if your house should be subject to the flood insurance requirement. On the other hand, if the Elevation Certificate states in Box B8. that your building is in Zone B, C, or X (not in an SFHA,) then we would be happy to contact the surveyor to try to resolve the question.

See CoreLogic's Flood Compliance Kit for more information on the LOMA process. 



In communities that participate in the NFIP, a flood insurance policy may be purchased from one of these sources: a licensed insurance agent or broker in good standing in the State in which the agent is licensed or an agent representing a Write Your Own (WYO) company that is authorized to sell flood insurance policies.

The process works as follows: (1) The agent and the applicant complete the flood insurance application; (2) The applicant provides necessary documentation, such as an Elevation Certificate; and (3) These documents and the full premium are sent to the NFIP or provided to the WYO; (4) The insurance policy is issued.

Flood insurance purchased through the NFIP provides the most comprehensive insurance protection available against flooding. The policy pays for direct physical loss to the insured building by or from flood damage, excluding personal contents. (Personal contents coverage may be purchased separately.) Additionally, a loss in progress is not covered by a new flood insurance policy. Be sure to review the flood insurance policy in detail to confirm what is covered and what is excluded.

Flood insurance through the NFIP is limited to the statutory limits (currently $250,000 structure/$100,000 contents for residential buildings; $500,000/$500,000 for non-residential). For property owners seeking additional coverage, "excess flood" coverage may be available. Unlike federal flood insurance, excess flood policies are underwritten by private carriers, so the amount and limitations of coverage varies. One company may write policies up to $75 million; another $1 million; another may only offer $250,000 above the NFIP limit. Annual premiums may range from a few hundred dollars to several thousand dollars.

For new insurance policies, there is a standard 30-day waiting period; the policy becomes effective on the thirtieth calendar day from the date of the application and the presentment of payment, provided that the NFIP receives the application and payment within 10 days of the application date. The Congressional intent behind this statutory waiting period is to prevent the purchase of flood insurance at times of imminent flood loss.

However, if the application for flood insurance is associated with loan activity, a requirement by the lender, or the remapping of the subject property's community, then the 30-day waiting period does not apply. If the purchase of flood insurance is in connection with the making, extending, increasing, or renewing of a loan, then the flood insurance becomes effective at the time of loan closing, provided that the application and the presentment of payment is made at or prior to loan closing.

In cases where a lender determines that flood insurance is required of a mortgagor who does not currently have insurance on the property, then the flood insurance policy becomes effective upon the completion of the application and the presentment of payment. When a property is remapped and placed into a Special Flood Hazard Area, then completion of the flood insurance application and presentment of payment made within 13 months of the map revision date will make the policy effective as of the day following the application and payment date.

Flood insurance rates are set by the NFIP; therefore, an NFIP representative, WYO carrier or independent agent should quote the same premium. Flood insurance premiums are determined by a building's age, design, occupancy, flood zone, and building elevations compared to flood elevations (for buildings within the Special Flood Hazard Area.) The premium is also based on the amount of coverage purchased and can be lower or higher depending on the community's status. Keep in mind that the NFIP adds standard fees to all policies.

For more information on rating a policy or on locating an insurance agent in a particular area, visit FEMA's FloodSmartwebsite.

An Elevation Certificate, or other elevation documentation certified by a surveyor or engineer and authorized by FEMA, is required if the building is post-FIRM, located within a Special Flood Hazard Area, and within a community that participates in the NFIP's Regular Program.

For insurance rating purposes, the date of construction or date of substantial improvement (the date the permit was issued provided that construction begins within 180 days of the permit date) is utilized to determine if a building is considered "pre-FIRM" or "post-FIRM."

A building is considered pre-FIRM if the start of construction or substantial improvement was on or before December 31, 1974, or before the effective date of the community's initial Flood Insurance Rate Map. Therefore, a post-FIRM building is one with a date of construction, or substantial improvement, after December 31, 1974 or on or after the effective date of the community's initial Flood Insurance Rate Map.

The NFIP offers a Standard Flood Insurance Policy and a Preferred Risk Policy. The Standard Flood Insurance Policy has three policy forms: the Dwelling Form, General Property Form, and Residential Condominium Building Association Policy Form (RCBAP). Each policy form applies to properties based on the ownership type and occupancy.

The Preferred Risk Policy applies, with certain conditions, to owners and tenants of eligible buildings located in the low to moderate-risk zones of B, C, and X in communities that participate in the Regular Program.

The Dwelling Form covers only non-condominium residential buildings built principally as a dwelling for one to four families or for a single-family dwelling unit within a condominium building. The Dwelling Form pays losses on Replacement Cost value for buildings used as primary residences, which are insured at least to 80% of the building's replacement cost. Separate contents coverage for personal property inside a building at the subject property is available for purchase with this form, as well.

The General Property Form covers commercial buildings or residential buildings that are not condominiums, including timeshares and cooperatives. Losses are handled on the basis of the building's Actual Cash Value. Contents coverage is available for these buildings.

The Residential Condominium Building Association Policy (RCBAP) is specifically designed for condominium associations to insure residential condominium buildings and its commonly owned elements. This policy covers condominium buildings located within communities that participate in the NFIP's Regular Program and have 75% or more of the floor area dedicated to residential use. These buildings can be detached single-family buildings, row houses, townhouses, or low-rise and high-rise buildings.

An elevation certificate is generally needed for one of two reasons:
1) In order to determine the correct premium for a flood insurance policy.
2) When a property owner wishes to apply for a Letter of Map Amendment with FEMA to have their home or other structure officially "removed" from a SFHA.



FACT: Homeowner's insurance does not cover flood damage. Federal flood insurance can only be purchased through an insurance agent, insurance company or the NFIP

FACT: FEMA disaster aid is only available if a Presidential Disaster is declared, which often does not happen after localized flooding. Even still, federal aid is not free. It's usually in the form of a loan from the Small Business Administration that must be paid back with interest. The best protection is a flood insurance policy, which pays claims regardless of a Presidential Disaster declaration.

FACT: Floods can occur anywhere. More than 25% of the flood insurance claims paid by the NFIP are for structures located outside of the identified floodplains (Special Flood Hazard Area). For properties located outside of the Special Flood Hazard Area (SFHA), flood insurance can be obtained at a substantially reduced rate. Also, if you obtain flood insurance while the property is shown outside of the SFHA, and subsequently, the flood map changes and places the property inside of the SFHA, your policy can be "grandfathered", and you will continue to pay the lower rate.

FACT: If a property owner's community is participating in the NFIP, then flood insurance may still be purchased. Only in extreme cases, in which the community, the property owner and FEMA are involved, would flood insurance coverage not be available for a property in a participating community.

FACT: When people do not buy flood insurance and a flood disaster strikes, the federal and state disaster relief comes from our tax dollars. Flood insurance is one of the best ways to keep disaster relief costs down for all taxpayers.

FACT: Flood insurance is available in participating communities to protect homes, condominiums and nonresidential buildings-including farm and commercial structures-regardless of whether they are in or out of the floodplain. In addition, contents coverage is available, which means renters can protect their possessions as well through a contents only policy.

FACT: As long as the property is in a participating community, federal flood insurance can be purchased at anytime. However, unless the lender requires the flood insurance, there is a 30-day waiting period after an application is submitted and the premium must be paid before the policy is in effect. The policy will not, however, cover a loss in progress.

FACT: Federal flood insurance can be bought through most major private insurance companies and property insurance agents.

FACT: The NFIP does offer coverage for basements, which it defines as any area of a building with a floor that is sub-grade or below ground level on all sides.

Basement coverage under an NFIP policy includes clean-up expenses and repair or replacement of items used to service homes and buildings. This can include elevators, furnaces, water heaters, air conditioners, utility connections, circuit breaker boxes, pumps and tanks used in solar energy systems.

Flood insurance will not cover the contents of a finished basement and basement improvements such as finished walls, floors and ceilings.

FACT: Flood insurance through the NFIP is reasonably priced with premiums for properties in the SFHA between $500 and $800 per year in many cases. For properties located in low risk areas (Zone B, C, or X), the premium is likely to be between $200 and $400 per year. Compare this to the cost of a low-interest disaster assistance loan, which must be repaid at about $300 to $400 per month!



According to the federal regulations, the flood zone determination must be based upon the current FEMA Flood Insurance Rate Map (FIRM). The foundation of our flood zone determination process is a multi-level database, which is based on two complementary processes. The first component is a vast database of nearly three decades worth of manually completed determinations. These determinations are created when one of our research analysts examines the FIRM and renders a determination. The analyst may also use other resources from our extensive library to locate the specific structure on the FIRM. These resources can include tax maps, plats, surveys, subdivision maps, lot and block information, section/township/range, aerial photographs, and legal descriptions.

The second building block in our process is state-of-the-art Geographic Information Systems (GIS) technology, which is a computerized mapping approach that gives us a digitized data view of a geographic location. This technology allows us to process map revisions quickly and efficiently and serves as a built-in check and balance system for maintaining superior accuracy.

On a nationwide average, the vast majority of our determinations are returned to you instantaneously, with the remainder manually researched and returned in less than 24 hours. Our current national average exceeds a 90 percent instant response with manually researched items completed in an average of 12 hours.

The information required to prepare an accurate flood determination is a correct and valid property address. Occasionally, we may require additional information such as the legal description, tax parcel number, tax identification number, and survey or site plan showing the physical location of all structures on the property. We utilize our expansive resource database to complete flood determinations prior to requesting any additional information, but we welcome any information that you have regarding the property.

Because we know your time is valuable, our goal is to provide such flawless service so as to minimize any questions or concerns. Should you need to contact us, however, you'll have immediate access to a friendly, knowledgeable Client Services Representative who will answer your question or rectify the problem as quickly as possible. Your call is answered without complicated phone menus or endless on-hold waits. Best of all, because of their training and authority, our Client Services Representatives can resolve 80% of phone (800-447-1772) inquiries on the spot, with no additional calls or follow-up needed. We are available from 7 a.m. - 7 p.m. Central time, Monday through Friday.

If you are ever faced with a flood-related regulatory complaint or violation, please contact CoreLogic immediately. We encourage you to contact us through our Client Services Department, your Account Manager, or the Compliance Department. Because we take an active role in the resolution, the sooner we become involved in the process, the greater the likelihood that we can help to resolve the matter.

We will work directly with you and the agency, commission, department, or other regulatory body to resolve the situation.

We understand that the need for rush service on a determination will arise from time to time. As a normal part of our customer service, we provide an expedited determination whenever the need arises. For an additional fee we guarantee a turnaround time of four business hours.

The federal regulations specify that the lending institution has the ultimate responsibility to require flood insurance when applicable; thus it behooves the lender to review the flood determination along with any other loan documentation and to contact CoreLogic with any conflicting information. When this occurs, we will review the flood determination to confirm the property's flood zone. Please also provide us with any conflicting documents, so we can respond directly to this information.