Can I get a 2nd opinion here:

We have CRE deal with 3 structures only one structure is within the flood zone. The appraisal provided us with the values per building including depreciation. For all CRE we calculate ACV (RCV - Depreciation = ACV)

Its been a while since I have worked on a CRE with this low of value, we normally max out at $500 so I wanted to be sure this looks right.

Loan amount is $408,000
Total property value is $2.25mm
Building in flood zone RCV $444m
building in flood zone depreciation $388m
building in flood zone ACV = $56,000
*Flood insurance required will be $56,000*

Correct

Based on my opinion, I believe the appropriate amount should be $444k (RCV) since I have not come across any information indicating that the ACV is the correct limit. Please refer to the following source:

https://www.helpwithmybank.gov/help-topics/mortgages-home-equity/flood-insurance/flood-above-minimum.html#:~:text=the%20insurable%20value%20of%20the%20structure%20(typically%20the%20replacement%20cost%20value%20of%20your%20home).

Non-residential buildings must update the replacement cost valuation every 3 years under the Program's requirements to ensure sufficient insurance coverage (look under Appendix I.23): https://www.fema.gov/sites/default/files/documents/fema_nfip_flood-insurance-manual_042024.pdf

The BRCV might be required to be updated by the insurance agent every three years, but the NFIP policy will only pay up to the actual cash value unless you are dealing with a dwelling policy on a primary residential structure or an RCBAP.