If we make a loan on secured by three different condominium units all located in the same building, do we need a separate flood determination (also known as a flood certificate) for each unit? All three units are located in the same building, under one address, and all three are being purchased simultaneously.

No, we believe that obtaining one flood determination for the building will be sufficient, unless more than seven years have passed or the applicable flood maps have been revised since the original flood determination was obtained.

The flood insurance regulations require lenders to obtain a flood determination whenever a building (or mobile home) will be collateral securing a loan. Because this responsibility applies to buildings, and not to individual units within buildings, we do not believe it is necessary to obtain more than one flood determination per building. We discussed this question (without using identifying information for you or your bank) with an expert at the National Flood Insurance Program (NFIP), who confirmed that flood determinations generally will cover an entire building and are not limited to a single unit within a building. There are some exceptions, such as for townhouses that are connected but have separate firewalls, utilities and addresses. But in this case, where all three condominium units are located in the same building and share a single address, the flood determination likely will cover the entire building (and you may be able to confirm this fact by reviewing it).

For resources related to our guidance, please see:

  • FDIC Flood Insurance Regulations, 12 CFR 339.6(a) (“An FDIC-supervised institution shall use the standard flood hazard determination form developed by the Administrator of FEMA when determining whether the building or mobile home offered as collateral security for a loan is or will be located in a special flood hazard area in which flood insurance is available under the Act. . . .”)