We are extending a loan secured by property located in a flood plain. There is a “hoop building” on the property with an arched metal frame covered in fabric. The hoop building does not have a concrete foundation and is removable. Is flood insurance required, and if so, in what amount?

No, flood insurance is not required for the hoop building since it is not a “building” according to the flood insurance regulations.

Flood insurance is not necessary for a structure that is not a building or mobile home. The flood insurance regulations define a building as “a walled and roofed structure . . .  that is principally above ground and affixed to a permanent site.” The FEMA Flood Insurance Manual also provides that the structure must have two or more “outside rigid walls.”

Since the hoop building lacks two outside rigid walls and is not permanently affixed to the ground, it is not a “building” requiring flood insurance.

For resources related to our guidance, please see:

  • FDIC Flood Insurance Regulations, 12 CFR 339.2 (“Designated loan means a loan secured by a building or mobile home that is located or to be located in a special flood hazard area in which flood insurance is available under the Act.”)
  • FDIC Flood Insurance Regulations, 12 CFR 339.2 (“Building means a walled and roofed structure, other than a gas or liquid storage tank, that is principally above ground and affixed to a permanent site, and a walled and roofed structure while in the course of construction, alteration, or repair.”)
  • FEMA Flood Insurance Manual, General Rules, page 3 (“Insurance may be written only on a structure with 2 or more outside rigid walls and a fully secured roof that is affixed to a permanent site.”)