Flood Insurance Compliance Checklist

Run every loan file through the federal flood-insurance checklist - SFHDF and flood zone, mandatory-purchase trigger, coverage adequacy, borrower notice, escrow, and force placement - with a pass/fail per requirement and a cited exception log.

Banking / Lending

What it extracts

14 extraction fields

Loan and Property Overview
A one-look roll-up of the loan and collateral - borrower, property, transaction (MIRE) type, loan amount and balance, and property type - so a reviewer can orient and so later tests know the applicable NFIP limit and escrow rules.
Flood Zone Determination (SFHDF) Review
Reads the Standard Flood Hazard Determination Form (FEMA SFHDF) and captures the community name and number, flood zone, SFHA indicator, and NFIP participation status - the determination that must be obtained and retained for the life of the loan.
Property in Special Flood Hazard Area
A single flag - true when the flood zone is an A or V zone (a Special Flood Hazard Area), the condition that can trigger the mandatory purchase requirement; false for X/B/C and, with a caveat, for undetermined D zones.
Mandatory Purchase Requirement Applicability
Decides whether the FDPA mandatory purchase requirement attaches - SFHA plus a participating community, minus the statutory exemptions (small loan, state-owned self-insured, and the HFIAA detached-structure exemption).
Flood Compliance Checklist
The requirement-by-requirement checklist - one row per FDPA obligation (determination, notice, coverage, policy type, escrow, force placement) with its status, governing citation, and where the evidence appears in the file.
Flood Insurance Coverage Adequacy
Computes the required minimum coverage as the lesser of the outstanding principal balance, the NFIP maximum for the property type, and the building's insurable value, and tests whether the carried building coverage meets it - the core adequacy check under 12 CFR 22.3.
Flood Insurance Policy Verification
Verifies the policy or declarations page - policy type, number, coverage limits, deductible, and effective and expiration dates - and confirms the named insured and property address match the borrower and the secured property.
Private Flood Insurance Acceptance
For a private (non-NFIP) policy, determines whether the lender must accept it under mandatory acceptance - including the compliance-aid statement and the at-least-as-broad-as-NFIP test - or whether it is a discretionary or mutual-aid acceptance.
Condominium (RCBAP) Coverage
For a condominium unit, assesses whether the association's Residential Condominium Building Association Policy (RCBAP) meets the 80-percent-replacement-cost or maximum-available standard and whether any unit-owner policy closes the gap.
Borrower Notice Timing
Tests the Notice of Special Flood Hazards - provided a reasonable time before closing (measured against a common 10-day policy benchmark), acknowledged by the borrower, and containing the federal disaster-relief availability language.
Escrow of Flood Insurance Premiums
Determines whether flood premiums must be escrowed (residential improved real estate, MIRE event on or after 01/01/2016) after applying the small-lender and loan-type exceptions, and whether escrow was established.
Force Placement Status
Where coverage was absent or insufficient, checks the force-placement steps - borrower notified, the 45-day period observed before placement, coverage force-placed, and any overlap premium refunded.
Compliance Determination
Rolls the individual checks into a single verdict for the file - compliant, deficient for insufficient or no coverage, deficient for a missing determination or notice, deficient for escrow, or needs manual review - taking the most severe when several apply.
Exceptions and Remediation Notes
The exception log - one row per failed requirement with its cited regulation section, a severity, the finding with observed-versus-required values, and a concrete remediation step - the workpaper the reviewer and remediation team act on.

Where it fits

Loan-file flood-insurance compliance review

Upstream

Loan origination and closing - the SFHDF, borrower notice, flood policy declarations, and closing package are assembled as the loan is made, increased, extended, renewed, or purchased

This step

Flood Disaster Protection Act compliance review of the loan file

Downstream

  • Exception tracking and remediation (coverage-shortfall notices, updated determinations, escrow setup, force placement)
  • Loan boarding and servicing setup
  • Regulatory examination preparation and audit

What it needs

Documents

  • Standard Flood Hazard Determination Form (SFHDF) or vendor flood determination certificate
  • Notice of Special Flood Hazards and borrower acknowledgment
  • Flood insurance policy or declarations page (NFIP or private)
  • Note, security instrument, and closing disclosure
  • Internal flood compliance checklist or procedures

Systems

  • Loan origination system
  • Flood determination vendor platform
  • Document repository or imaging system
  • Compliance / GRC workpaper system

Prerequisites

  • The flood determination (SFHDF) for the secured property
  • The flood insurance policy or declarations page in effect at closing
  • The lender's asset size and escrow-policy history (to apply the small-lender escrow exception)

What it produces

A per-loan-file flood-compliance result - pass/fail per checklist requirement, the coverage-adequacy math, the cited regulation section, a single compliance determination, and an exception log with severities and remediation steps

Delivered to

  • Exception / remediation tracker
  • Compliance workpaper / GRC system
  • Loan file / imaging system

Review model

A flood-compliance analyst reviews each flagged exception, the coverage-adequacy math, and the cited regulation section before a loan file is cleared or routed for remediation.

Who uses it

Flood Compliance AnalystLoan Compliance ReviewerConsumer Compliance AnalystRegulatory Compliance ManagerInternal Audit ReviewerPost-Closing QC Reviewer

Volume fit

Works best for

lenders and compliance or QC teams checking hundreds or thousands of loan files across a portfolio with flood exposure

Too small for

a portfolio with no properties in flood-prone areas, or a one-off single-file review

Grounded in

  • Flood Disaster Protection Act of 1973, as amended (42 USC 4012a) - mandatory purchase requirementverified as of 2026-07-22
  • Interagency flood regulations - 12 CFR part 22 (OCC national banks), part 172 (federal savings associations), part 208 / 208.25 (Federal Reserve member banks), part 339 (FDIC), and part 614 subpart S (Farm Credit)verified as of 2026-07-22
  • 12 CFR 22.3 / 339.3 / 208.25(c) - required amount of flood insuranceverified as of 2026-07-22
  • 12 CFR 22.9 / 339.9 / 208.25(i) - Notice of Special Flood Hazardsverified as of 2026-07-22
  • 12 CFR 22.5 / 339.5 / 208.25(e) - escrow of flood insurance premiums (HFIAA)verified as of 2026-07-22
  • 12 CFR 22.7 / 339.7 / 208.25(g) - force placement of flood insurance (Biggert-Waters)verified as of 2026-07-22
  • Private flood insurance final rule (interagency), effective July 1, 2019 - 12 CFR 22.3(a) and parallel partsverified as of 2026-07-22
  • Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) - detached-structure exemptionverified as of 2026-07-22
  • Standard Flood Hazard Determination Form (SFHDF), FEMA Form FF-119-FY-22-128 (formerly FEMA Form 086-0-32)verified as of 2026-07-22

Changelog

  • July 2026

built to industry best practice for federally regulated mortgage lenders' flood-insurance compliance under the Flood Disaster Protection Act

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