No, we believe that obtaining one flood determination on the property for both loans will be sufficient.

The flood insurance regulations require lenders to obtain a flood determination whenever a building (or mobile home) will be collateral securing a loan. A lender may rely on a previous flood determination when a new loan is secured by the same property if it is not more than seven years old, and the basis for the previous determination is set forth on the required form. Since the first and second mortgage loans will occur on the same day, you are well within the timeframe to rely on the flood determination obtained in connection with the first mortgage loan for the second mortgage loan.

For resources related to our guidance, please see:

• FRB Flood Insurance Regulations, 12 CFR 208.25(f) (“A state member bank 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. . . . ”)

• National Flood Insurance Act, 42 USC 4104b(e) (“Any person increasing, extending, renewing, or purchasing a loan secured by improved real estate or a mobile home may rely on a previous determination of whether the building or mobile home is located in an area having special flood hazards (and shall not be liable for any error in such previous determination), if the previous determination was made not more than 7 years before the date of the transaction and the basis for the previous determination has been set forth on a form under this section, unless . . . [certain exceptions apply].”)

• Interagency Q&As Regarding Flood Insurance (July 21, 2009), Question 68 (“ . . . if the same lender makes multiple loans to the same borrower secured by the same improved real estate, the lender may rely on its previous determination if the original determination was made not more than seven years before the date of the transaction, the basis for the determination was set forth on the SFHDF, and there were no map revisions or updates affecting the security property since the original determination was made.”)