We have a scenario where our bank requested a flood determination, and it came back in zone AE.

We were advised by the borrower that there was a LOMA so we pulled the case # from FEMA and submitted it to the vendor for a recheck.

The original LOMA was issued in 2013, and in 2021 a FIRM update occurred.

The LOMA was revalidated following this map update, but our vendor is stating they cannot accept this LOMA to update the flood zone for the following reason- "... our policy is that any LOMA that was issued “OUT AS SHOWN” is no longer valid once the flood map is updated when the building is in the flood zone on the new flood map".

Per FEMA, the issuance of a LOMA eliminates the flood purchase requirement. It is my belief that FEMA has the final say and this LOMA must be accepted, but we have never had a vendor push back on this. At this point I have pleaded the case and they are declining to update the determination to reflect the LOMA.

Has anyone experienced this? I believe I have pleaded my case sufficiently so I am wondering if there is anything else I should consider.

thank you!

I assume that you have shown them this? https://emilms.fema.gov/is_1119/groups/136.html

You might also want them to take this test and see how they do. https://emilms.fema.gov/is_1119/groups/138.html

If that does not work, then tell them you are seeking a LODR and if they are wrong, you are going to make them pay the $80: https://www.fema.gov/fact-sheet/how-request-flood-hazard-determination-review-fema

If anyone is interested in where the first two links came from, it is from the FEMA Online Study Course on the subject of map amendments.

https://training.fema.gov/is/courseoverview.aspx?code=IS-1119&lang=en

I did include information that is similar to what is detailed in that first link regarding the revalidation process, but I will actually provide this link since it comes directly from FEMA.

I appreciate the second link, which I had not seen before and I found helpful as well.

I did mention that we would like to avoid the LODR due to the cost, so perhaps your suggestion will entice them to cooperate.