If someone tells you they have a simple LOMC question, you might want to cancel your plans for the afternoon. That was the half-joking premise of the National Flood Association’s recent webinar, A Deep Dive into FEMA’s Letters of Map Change, featuring Jennifer Haun of ServiceLink National Flood, Gerry Evenwell of National Flood Experts, Andy Yesaitis of Western Technologies Group, and Derik Pierson, Research Director at AFR Services. Here are five takeaways for lenders.
Derik started with a distinction that shapes everything else: the Standard Flood Hazard Determination Form, better known as the flood zone determination, is a compliance document for the lender, not a due diligence document. Because it must be based solely on the effective FEMA map or its latest effective revision, the real question is whether a LOMA is still the most current record. When documents conflict, the most recent effective date takes precedence.
That principle explains several rules that trip up lenders. A LOMA can be superseded by a later LOMR or panel revision. A LOMR, in turn, doesn’t count until its effective date arrives. When a revised map takes effect, older LOMAs lapse unless FEMA lists them on a revalidation letter. For the same reason, an elevation certificate alone can’t overturn a determination. It’s an official FEMA document used for insurance rating and to support a LOMC request, but only a LOMC actually revises the map or removes a structure from the Special Flood Hazard Area.
His example from Watertown, South Dakota: a 2011 LOMA removed a structure, a 2023 LOMR put it back in, and a new LOMA took it out again. Only the newest document controls. And when a determination says a property is out but the map shows it in, it’s usually because LOMA results aren’t drawn on the map panel.
Andy noted that the dot marking a LOMA on FEMA’s National Flood Hazard Layer only shows that a record exists. The determination document defines what’s covered, and one point can represent dozens of structures, some removed and some not. The panel also showed “Out As Shown” letters that were revalidated in error or named the wrong structure. Read the document, not the dot.
Gerry estimated a 40 to 50 percent error rate on MT-1 submissions. A missing comma in a legal description can send one back, and FEMA reviewers who see new development nearby may require a full MT-2 instead. A borrower who says “we’re filing a LOMA” may face a longer road than expected.
Under Risk Rating 2.0, the map decides whether insurance is required, while the rate prices each building on roughly 40 factors, including drainage area, elevation, and distance to water. A LOMA changes the mandatory purchase answer but not the rating.
Gerry pointed to Camp Mystic in Kerr County, Texas. A 2013 LOMA correctly placed the cabin floors above the BFE, yet Risk Rating 2.0 priced them at roughly $6,000 a year each, about five times the median NFIP full-risk premium, reflecting a flash-flood-prone canyon setting. The devastating July 4, 2025 flood rose well above those floors. The map was accurate. The rating was the signal. His advice: pull the Risk Rating 2.0 quote for any property that matters.
LOMCs are snapshots. A removal today can be superseded tomorrow, which is why accurate determinations backed by life-of-loan monitoring matter long after closing. AFR’s determination team works through these scenarios every day. If you have a LOMC question that turned out not to be so simple, we’re glad to help.