Bank is making loan to develop a new golf course including construction of a club house and other building on the grounds. The portion of the land that is in a flood zone will be used to build one of the bathrooms and a pump station. Construction on these (allegedly) won't be started until well after the rest of the major construction is close to completion. Per the FAQs, the Bank can defer the purchase of flood insurance until after the foundation slab has been poured or an EC is obtained, and disbursement can't occur until flood insurance is in place.

Does this deferment apply to the slab/EC requirement for the 2 structures to be located in the flood zone rather than the structures not in the flood zone? I hope this is what the FAQ means.

If you can prove that none of the disbursements made were for those two buildings, then I think you could make an argument that you are in compliance. Just remember, if the policy is not purchased before or at loan closing, there is a 30 day wait on the effective date of the policy, so they are going to have to front run purchasing a policy before the beginning of any construction on those two buildings.