Flood Zone

[Mike Ault]

Don't change it. If you will read that flood determination carefully, you will notice that it limits its analysis to "the dwelling & related improvements". That is not what we are appraising. We are appraising the entire site, not just "the dwelling and related improvements" and although they may have gotten enough fill dirt to raise the pad above the base flood hazard elevation I've never seen anybody bring enough fill dirt in to raise the entire site above said elevation. I've run into this often, always held my ground, and slept securely knowing that I obviously know a lot more about underwriting appraisals than my client. There was a story posted on here about some appraiser getting sued for $250,000 because he trusted one of those flood determinations on a suburban 10 acre site and some borrower later decided to install a nice barn on the property after closing. Well, of course they decided to install it down by the creek bed where all the pretty trees were and it was washed away shortly thereafter. However, they waived their appraisal around in court clearly showing that the appraiser said "their property was not located in a flood zone" and that barn should've been safe from flooding. They prevailed in court, not sure what the monetary settlement ended up being but that appraiser probably didn't sleep for awhile and I will guarantee that he never, ever changed another flood zone classification based on the lenders "flood determination".

 

[Tom D]

Well interesting. I would get their paper work in report. State according to it, the house itself is not in a flood zone as per the lenders sent cert, but parts of the property are in a AE plain. Then you are covered both ways. And you do not guarantee that this is 100% true. Noted, that the buyer should do their own flood search to verify. Sorta like FHA saying to the buyer, get your own home inspection to be sure.

 

[JTip]

There is ONE source for flood data, it is FEMA.

All providers get their info from FEMA.

If FEMA says its in a flood zone, then it is in a flood zone.

 

[sputnam]

I got a revision from a lender (not an AMC). I did an appraisal on a property that is in a flood zone. (It's a sale, not a refi) I said that it was in the report and added the flood map. They have sent it back 3 times telling me to change it from AE to X and that it is not in a flood zone because Corelogic told them so and provided a page to prove this. not that all these sources hold water but, MLS data, IMAPP, Realist, property records and FEMA say flood zone AE. They are still coming back for a 4th time telling me I need to change it to X. I called FEMA today and they said that it is in fact AE zone and so is everything around it. (It's not like it's on the cusp of not being in that zone). The whole map is lit up blue for AE everywhere around the house. The lender is still hounding me. I explained in the revision that I did not make any changes and why. I also listed all the sources. This is not the first time I've been pushed in the corner with this "well, Corelogic says so" revision. This time though, they aren't taking no for an answer. I refuse to change it. What do you all think I should do at this point to shut them up. They keep coming back with the same revision. I know I will wake up to another one in my email in the morning,

The only thing you can do is explain your research and results. Straight up tell them that based on.. whatever you used... Corelogic is wrong. I've seen flood determinations by Corelogic (and others) be incorrect before. If they want a definitive determination, they will need to pay for a survey.

 

[ucbruin]

At the end of the day, it's only a real life issue....
If there's a flood....

 

[Vermonter]

I would request lender forward copy of Flood Certification and Zone. Then attach that to your report and change report to the Cert Zone.

This is the answer right here. Areas are remapped all the time and aren't always reflected in the FEMA data. Attach the docs (provided you believe they are reliable), disclose everything you found and disclaim.

 

[BRCJR]

The lender is required to obtain a flood certification before the loan closing. Tell them you are not going to change what YOUR due diligence has determined and that the fact the Appraisal Report differs from what they say has no material impact on the overall credibility of the report.

Tell them to use the flood certification they pull and move on.

 

[TerryRohrer]

As Mike noted above, we are asked about "the property" not, "the improvements". The FEMA website, which is so straight forward (light years ahead of the old, 1,000+ flood map collections we used to maintain) that you simply have to enter an address. That website includes the following statement:

"About Flood Map Service Center
The FEMA Flood Map Service Center (MSC) is the official public source for flood hazard information produced in support of the National Flood Insurance Program (NFIP). Use the MSC to find your official flood map, access a range of other flood hazard products, and take advantage of tools for better understanding flood risk.

FEMA flood maps are continually updated through a variety of processes. Effective information that you download or print from this site may change or become superseded by new maps over time. For additional information, please see the Flood Hazard Mapping Updates Overview Fact Sheet"

When you enter an address, the map appears on your screen along with the information pictured below. Any modifications approved by FEMA should show up in the Revisions, Amendments, and/or Revalidations folders with any details that might be pertinent, including any Letters of Map Change (LOMAs). I would not accept any flood certification that I could not support with the information here. I have a community that I have appraised in since 1987 where large areas have not been mapped. I continually have to respond to requests to change my reports to reflect "certifications" that reflect these areas are not in a flood zone. That is false, as the determination has never been made (a community choice last time I delved into the matter).

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[Tom D]

If the lender has something that says this, or dat, you use it with a disclaimer of your own. Let the buyer understand the issue, so they can't come back to you personally.

It's like outdated public records. Are you going to hang yourself on what you think is right. Or just include everything with a caveat. And if the lender is right and you aren't, then you get a possible law suite or referral to state. The only safe route is full disclosure of what is being seen by whom, and why. And yes, areas that never flooded, flooded recently with these storm rivers of rain.

You put it all on a separate addendum in your report so it can't be missed. Buyer beware.

 

[sputnam]

This is the answer right here. Areas are remapped all the time and aren't always reflected in the FEMA data. Attach the docs (provided you believe they are reliable), disclose everything you found and disclaim.

Since FEMA is the authoritative source for Flood Hazard Zones, that's nonsense unless you are using paper flood maps to make your determination.