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The 5/11/2022 new FDPA FAQ, Question Zone 1 states that banks are not required to investigate or resolve flood zone discrepancies between the flood determination and the proof of flood insurance coverage. Is there anything we must document to allow a discrepancy, and does it cover any type of zone discrepancy, for example a V-E flood determination with a C declarations page?
Our third party flood insurance tracking company has not implemented this and is requiring bank approval to accept a flood insurance policy with a zone discrepancy. I have asked about it, but the company just says they have not implemented that, there is no change in their procedures yet. Is there any documentation or additional step I should take to support approving accepting the flood zone C policy on a V-E determination?
You are correct; the new Q & As do not require you to do anything in the event of a discrepancy. The proposed Q & As required you to document the discrepancy but did not require any further action. We believe document the discrepancy is still a good practice.
There is concern that if the consumer has underpaid the insurance premium, the deficiency would be assessed by FEMA on any loss payout in the event of flood damage.
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