Lesson 6 Objectives
At the end of this lesson, you will be able to:
  • Identify the benefits of maintaining insurance after receiving a LOMR approval
  • Recognize the connection between LOMRs and mandatory purchase of flood insurance
  • Recognize the different degrees of risk remaining after an LOMR is issued
You Have Your LOMR; How Long Will It Be Valid?
LOMRs
  • LOMRs and LOMR-Fs do not expire, but they can be superseded by a new FIRM

LOMR-Fs

  • LOMR-Fs are transferable to future owners
  • When FEMA prepares to revise an effective FIRM, all the LOMRs that are affected by the revision are reviewed and incorporated as appropriate
  • When preparing a Preliminary Map or revised map panel, FEMA sends a Summary of Map Actions (SOMA) to the community which identifies all the Letters of Map Change (LOMCs), including LOMRs and LOMR-Fs issued for a community, and whether:
    • The LOMR will be incorporated into the new FIRM
    • The LOMR or LOMR-F is likely to be superseded by new information on the FIRM and will no longer be valid
    • The LOMR-F is likely to be revalidated once the new panel is published
  • When the effective FIRM is issued, FEMA issues a Revalidation Letter which lists the LOMCs that have been reaffirmed for the new FIRM

 

 

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Note
The Revalidation Letter does not list the LOMRs that have been incorporated into the revised panel, LOMRs that are superseded by new or revised mapping, or LOMRs that are no longer valid.
Ways to Invalidate a LOMR
  • There are actions you can take that can cause a LOMR to become invalid:
    • Changing the landscape in a manner that increases flood risk, such as excavating an area that was a path for floodwaters (LOMR-F)
    • Removing certified protections from floodwaters (LOMR)
    • Expanding a structure to a portion of the parcel not included in a LOMR
  • If an updated FIRM panel supersedes a LOMR, the LOMR is invalidated. If a structure is then determined to be in the SFHA, the property owner will be required to purchase flood insurance
Residual Risk and Flood Insurance

The “100-year Flood” is an insurance standard and not a risk standard. The 1-percent annual flood risk actually means that a structure has a 26-percent chance of being flooded over the life of a 30-year mortgage.

Even with a LOMR-F, flood risk remains and homeowner’s insurance does not cover damages from floods. Flood insurance is available for nearly all structures, regardless of the flood zone. Structures outside high-risk zones may qualify for a more inexpensive Preferred Risk Policy. More information is available on Preferred Risk Policies at https://www.fema.gov/media-library/assets/documents/17576.

Some important points to remember about LOMR-Fs and flood insurance are:

  • A lender may require flood insurance even with a LOMR-F
  • After receiving a LOMR-F, the property owner may be able to receive a flood insurance refund if the lender allows the property owner to drop flood coverage
  • For LOMR-Fs, the policy may also be converted to a lower-cost Preferred Risk Policy if there has been no more than one claim over any 10-year period

For more information, watch the FEMA Value of Flood Insurance video, available at https://www.fema.gov/media-library/assets/videos/159672.

Insurance Options After a LOMR
  • Even though a LOMR revises the effective SFHA which affects the mandatory purchase requirement, it is still considered a good mitigation measure to have flood insurance. Where it rains, it can flood
  • Preferred Risk Policies (PRP) are available to structures with LOMAs and LOMR-Fs, are located in Zones B, C, X, AR or A99 on the effective date of the policy, and meet certain loss requirements
  • Preferred Risk Policies cover building and contents, or contents alone
  • Preferred Risk Policies are available to structures with LOMAs and LOMR-Fs which are located in Zones B, C, X, AR, or A99 on the effective date of the policy and meet certain loss requirements.
LOMRs and Degrees of Flood Risk

There are different degrees of risk. Consider risk and the likelihood of an event times the consequence of that event. You can have a high probability/low consequence event, such as a shallow flood that is slightly higher than the base flood. You can have a low probability/high consequence event, such as a failure of a dam or a flood control structure. We have seen with recent hurricanes, that deep or high-velocity flooding within the SFHA is a high probability/high consequence event.

A LOMR-F may remove a parcel or a structure from the SFHA, meaning that it would not be inundated by the base flood (1-percent annual chance flood). But that does not mean that there is no risk. More than 25 percent of all NFIP claims are from structures outside of the high-risk flood zones.

A LOMR changes the area subject to the base flood, but does not eliminate risk. As such, it should not be used as merely a means to “get out of” paying for flood insurance. FEMA recognizes that by offering low-cost Preferred Risk policies for structures outside of high-risk flood zones. It pays to use this low-cost flood insurance option to protect against the residual risks of flood damages.

Post-LOMR Resilience
  • Even after a LOMR is obtained, flood risk remains
  • Lower-cost flood insurance is available outside of the high-risk flood zone, as long as claims history conditions are met
  • Mitigating structures in flood zones and building new structures to higher standards significantly lowers flood risk and related flood insurance costs
Resources
Lesson 6 Review
  • LOMRs and LOMR-Fs do not expire, but they can be superseded by a new FIRM
  • LOMR-Fs remain with the property or structure until they superseded by new flood maps or by changes to the property
  • LOMR-Fs are transferrable to new owners
  • When FEMA updates a FIRM, all the LOMRs that are affected by the revision are reviewed and incorporated as appropriate
  • Ways a property owner can invalidate a LOMR
  • If an updated FIRM panel supersedes a LOMR, the LOMR is invalidated. If a structure in then determined to be in the SFHA, the property owner will be required to purchase flood insurance
  • Different degrees of flood risks remain after a LOMR-F is obtained
  • Flood insurance is always advisable and lower rates are available outside of high-risk flood zones