Sometimes what should be easy, just isn’t.

• In this example, the Borrower owned the pads and common area buildings of a mobile home community, but not the actual mobile homes.

• The Lender felt that the Borrower owned some of the mobile homes that were in a flood zone.

• Ancram Consultants reviewed the Borrower’s loan documents which indicated that the mobile homes were actually owned by an entity related to the Borrower and were not subject to the Lender’s flood insurance requirements. 

• The Lender agreed with the analysis and canceled the force placed flood policy.

• During a review of the Borrower’s multifamily property, the Lender noticed several structures in a flood zone that did not have flood coverage. One of these structures included a mail kiosk. The Lender felt that the structure was flood eligible based on an aerial view and eventually force placed insurance for building and contents. 

• Ancram Consultants conducted a site visit of the property and discovered that the mail kiosk had no interior access and only consisted of the mailboxes. The structure was documented with photos and an explanation. The Lender agreed that the structure did not require flood insurance and canceled the force placed policy. 

• During a review of the Borrower’s multifamily property, the Lender noticed several structures in a flood zone that did not have flood coverage. One of these structures included a maintenance shed. The Lender determined that the structure was flood eligible and eventually force placed insurance for building and contents. 

• Ancram Consultants conducted a site visit of the property and discovered that the maintenance shed was not permanently affixed to the ground and was not considered flood eligible. The structure was documented with detailed photos and an explanation. The bank agreed that the structure did not require flood insurance and canceled the force placed policy. 

• In this example, the Lender was conducting a flood review of their loan files that was focused on flood insurance for contents. The property in question was a multi-tenant office building.

• The Lender realized in their review that they had no evidence of who owned the contents inside the office building. The Lender sent a 45-day letter to the Borrower, but did not realize that the contact info for the property was no longer valid. The Lender force placed flood insurance for contents in the amount of $500,000. 

• The Borrower realized, through billing, that funds were being taken from their escrow account to pay for the force placed insurance. 

• Ancram Consultants contacted the Lender to discuss the Borrower’s situation and it was determined that an attestation from the Borrower was sufficient to resolve the issue. The Lender canceled the force placed policy and returned funds to the Borrower’s escrow account.    

• In this example, the collateral for a loan consisted of an off-campus student housing project located in a flood zone. The project consisted of a large covered sports-court. During one of its annual flood reviews, the Lender felt that this structure, as well as several others, were flood eligible and needed flood coverage. The Borrower’s insurance agent assured them that flood insurance was not needed. The Lender issued a 45-day letter notifying the Borrower that flood insurance was needed. At the end of the 45-day period, the lender force placed flood insurance for building and contents and began to draw funds from the Borrower’s escrow account. 

• Ancram Consultants conducted a site inspection of the property. It was determined that the structure was not flood eligible. Detailed photos and a report were prepared and sent to the Lender. The Lender agreed with the analysis and canceled the force placed policy. All funds were returned to the Borrower’s escrow account.   

• During a Lender flood review, a bank employee identified an owner occupied industrial property with a single flood policy as actually being 3 buildings. This review was done using satellite images. The Lender notified the Borrower that 3 $500,000 flood policies were needed. In addition, the Lender notified the Borrower that 3 flood policies for contents were also needed. 

• The Borrower responded to the Lender indicating that it was only one structure and that they had always had one flood policy since acquiring the property. The Lender did not consider this to be sufficient evidence, and a force placed policy was obtained. 

• Ancram Consultants performed a site inspection of the property. It was determined that the property was constructed over a period of several years which made the structure look like multiple buildings. During the site inspection, it was noted that although constructed over several years, the interior was open with no walls between structures. Detailed photos were taken documenting the interior. A report was prepared and sent to the Lender who agreed with the analysis. The Lender canceled the force placed policy.

• During a flood review, a bank employee notice a photo of a generator in the loan appraisal. The employee believed that if the generator was located inside a permanently affixed structure, the structure required flood insurance. A 45-day letter was sent to the Borrower notifying them that a flood policy was needed. 

• The Borrower disagreed with the Lender and explained that it was a generator and no flood insurance was required. The Lender disagreed and force placed both building and contents flood coverage.

• Ancram Consultants discussed the situation with the Borrower and requested that they take detailed photos of the generator and provide details regarding the make of the generator. After researching the generator and viewing the photos, it was determined that what was thought to be a separate structure, was actually part of the generator unit. A report, with detailed photos, was provided to the Lender who agreed with the analysis and canceled the force placed insurance.  

• In this case, the property consisted of a retail center. Various portions of the building were attached by an enclosed walkway. The Lender determined that this did not create a single building. A 45-day letter was sent to the Borrower informing them that one NFIP policy was not sufficient. The Borrower did not agree and explained that the construction was considered a single structure. The Lender was not satisfied with the Borrower’s response and force placed flood insurance for building and contents.

• Ancram Consultants performed a site visit of the property and determined that the walkways were permanently enclosed with rigid walls and a shared roof. In addition, the walls were considered load-bearing. Although this gave the Borrower the option to choose separate NFIP policies, the Borrower preferred to have the single NFIP policy. Detailed photos were taken of the property and a full report was prepared for the Lender. The Lender agreed with the analysis and canceled the force placed flood policy.