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Flood Waivers for 60 Yr. Old Homes

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Question: 
In reviewing the FEMA manual and Flood Act requirements, I don't see any carve-outs for old "placeholder dwellings" (dilapidated structures). Our policy has been that if they have two walls and a roof and they are in a flood zone requiring insurance, it must be purchased. We are running into insurance agents who are saying that homes have a lifespan of 40-60 years so if the home is 60 years old, that the percent of life left is 0 and as such, there is no Actual Cash Value, even when a picture of the dwelling shows it is still standing. Are you aware of any basis for accepting an agent's statement that there is $0 ACV based on the age of the home and lack of upgrades to avoid requiring flood insurance?
Answer: 

The insurance agents need a refresher course. There is no allowance in the regulation for waiving flood insurance other than the detached structure exemption.

Rich Slevin at a flood seminar about 18-19 years ago said the following—

If there is a building located in a SFHA that would fall down if you leaned against it you have 3 choices when it comes to flood insurance under the regulation:

  1. Require flood insurance
  2. Do not make the loan without flood insurance
  3. Lean against the building before making the loan.

First published on 05/08/2022

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