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#2278705 - 12/12/22 07:45 PM Conditional Letter of Map Revision
parr04 Offline
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Joined: Aug 2004
Posts: 394
oklahoma
Borrower has provided the bank with a Conditional Letter of Map Revision Based on Fill Comment Document.
It says "Please note that this is not a Final Determination. A final determination will be made upon receipt of As-Built information regarding this property".

Since this is "conditional" I feel we need to have flood insurance until this becomes final. Am I correct or can the borrower drop the current flood insurance based on the Conditional Letter of Map Revision?

This is the first one of these I have seen.

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Flood Compliance
#2278706 - 12/12/22 08:13 PM Re: Conditional Letter of Map Revision parr04
rlcarey Offline
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rlcarey
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Posts: 85,348
Galveston, TX
It does not impact the current need for flood insurance.

Conditional Letter of Map Revision (CLOMR)

FEMA's comment on a proposed project that would, upon construction, affect the hydrologic or hydraulic characteristics of a flooding source and thus result in the modification of the existing regulatory floodway, the effective Base Flood Elevations (BFEs), or the Special Flood Hazard Area (SFHA). The letter does not revise an effective NFIP map, it indicates whether the project, if built as proposed, would be recognized by FEMA. FEMA charges a fee for processing a CLOMR to recover the costs associated with the review. Building permits cannot be issued based on a CLOMR, because a CLOMR does not change the NFIP map.

Once a project has been completed, the community must request a revision to the Flood Insurance Rate Map (FIRM) to reflect the project. "As-built" certification and other data must be submitted to support the revision request.
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#2278707 - 12/12/22 08:13 PM Re: Conditional Letter of Map Revision parr04
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,875
Bloomington, IN
https://www.fema.gov/glossary/conditional-letter-map-revision-clomr

The letter does not revise an effective NFIP map, it indicates whether the project, if built as proposed, would be recognized by FEMA.

From what I can see until the LOMR becomes final the property is still located within a SFHA and would require the appropriate flood insurance coverage..
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#2278709 - 12/12/22 09:17 PM Re: Conditional Letter of Map Revision Dan Persfull
parr04 Offline
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Joined: Aug 2004
Posts: 394
oklahoma
Thanks for you quick response.
Doubt the borrower or the loan officer is going to very happy with me once I share the news.

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#2278711 - 12/12/22 10:04 PM Re: Conditional Letter of Map Revision parr04
raitchjay Offline
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Joined: Oct 2009
Posts: 9,364
OK
While i believe you, i don't understand why the LO should be unhappy. I'm always amazed at how invested some LO's get with trying to help borrowers evade flood insurance. The LO isn't helping to pay it, and would probably be pretty upset if the property flooded and left him with no collateral.
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#2278713 - 12/12/22 10:16 PM Re: Conditional Letter of Map Revision parr04
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,348
Galveston, TX
Plus, with as accurate as the maps are in recent events, the chances of this eliminating the property from actually flooding is likely zero.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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