Then the map changes due to a new flood map or Letter of Map Change (LOMC) being issued by FEMA.
Recent reporting from Howard County, Maryland illustrates how those changes can affect borrowers in both directions. Newly Revised FEMA maps would move some buildings into mapped floodplains and others out. For lenders, that creates a question that extends well beyond origination: How will your team identify affected loans and manage what happens next?
For the internal loan operations team, a map revision can become a substantial project. Each affected loan requires review, with insurance requirements to evaluate, borrower communications to manage, and records to update. Individual exceptions add complexity while the team works through the rest of the portfolio and its applicable deadlines.
Consider a borrower who responds to a flood-zone change notification with a Letter of Map Amendment (LOMA) and a reasonable question: “Didn’t FEMA already remove my building?”
The LOMA may resolve the issue. It may also apply to a different structure, have been superseded by a later map revision, or require additional review.
Before closing the exception, lenders need to establish three things: the right structure, the current document or flood map, and its effective date.
A property address or a point on a map can help locate a record. Neither establishes exactly what FEMA removed.
During the National Flood Association’s recent webinar, There’s No Such Thing as a Simple LOMC Question, panelists explained that a single LOMA map marker can represent multiple structures, with different outcomes for each. The LOMA determination letter defines what is covered.
For a servicing team, the practical question is whether the letter applies to the building securing the loan. A removal affecting one structure does not necessarily resolve the status of another building on the same property.
If a borrower’s LOMA appears to conflict with an updated determination, the lender’s team should gather the complete letter and its attachments, confirm which building it covers, and compare that information with the updated determination. A screenshot of a map marker alone does not establish whether the letter applies to the building securing the loan.
A valid removal at one point in time may no longer control today.
As AFR Research Director Derik Pierson explained during the webinar, subsequent map revisions can change the status of an earlier LOMA. His example followed a structure through a removal, a later revision that placed it back in the Special Flood Hazard Area, and another removal.
That sequence matters when a borrower’s records and an updated determination appear to disagree. The documents may describe different points in the building’s mapping history.
As discussed in the webinar, lenders should review the applicable effective map, subsequent revisions, and any relevant revalidation information before relying on an older letter.
An older LOMA deserves review—not an automatic dismissal or an automatic override of the updated determination.
“We’re applying for a LOMA” is different from “FEMA has issued a LOMA.”
The webinar highlighted mistakes that can delay applications, including incomplete or incorrect supporting information. Gerry Evenwell of National Flood Experts estimated that 40–50% of MT-1LOMA applications contain errors. That was his webinar estimate, but the operational lesson is straightforward: lenders should avoid assuming a pending application will be approved on the borrower’s expected schedule.
An elevation certificate, LOMC application acknowledgment, or LOMC conditional letter does not establish the same result as an approved and effective FEMA determination removing the building.
The effective date still matters. A pending request should be tracked separately from the lender’s current insurance requirements and applicable deadlines. If a borrower is pursuing a letter of map change while a coverage exception remains open, the team needs to manage both.
Receiving a LOMC document is a step toward resolution. The servicing record should also capture what the review established.
A useful review record answers:
If the review confirms that the building has been removed from the Special Flood Hazard Area, explain that the federal mandatory purchase requirement no longer applies and identify any remaining lender or investor requirements. The conversation should also make clear that removal does not eliminate flood risk.
If the LOMC is not yet in effect and required coverage remains missing or insufficient, continue the applicable notice and follow-up process.
AFR’s loan servicing solutions support lenders throughout this process. Life-of-loan monitoring identifies flood-zone changes resulting from newly revised FEMA flood maps and provides updated determinations. Insurance tracking helps manage coverage documentation, borrower communications, and outstanding insurance needs. When required coverage is missing or insufficient, AFR’s lender-placed insurance program provides a way to protect the collateral. Together, these services help lenders move from a change notification or borrower-submitted document to a documented resolution.
Request a demo to see how AFR can help your team resolve flood-zone questions, manage insurance follow-up, and protect your loan portfolio.