Upon receiving a completed MT-EZ (for LOMAs) or MT -1 (for LOMR-Fs) application, FEMA reviews property-specific information including surveyed elevation data; typically the elevation of the lowest adjacent grade of the structure in question, provided by a licensed land surveyor. (Note: The homeowner may be required to hire a licensed engineer or surveyor to perform this elevation survey, if this data is not readily available), and makes a final flood zone determination for the property. Once an application and all necessary data are received, the determination is normally issued within 30 to 60 days. If the LOMA or LOMRF removes the SFHA designation from the property, it can then be presented to the lender as proof that there is no federal flood insurance requirement for the property. However, even though a LOMA or LOMR-F may waive the federal requirement for flood insurance, a lender retains the prerogative to require flood insurance. No fee is charged for the review of a LOMA; however, there is a review fee for a LOMR-F. A listing of all fees associated with flood map reviews can be found on the FEMA website.
In addition, property owners may apply for a Letter of Determination Review (LODR). A LODR is a review of the lender's determination. In other words, the LODR is a process where FEMA reviews the same information the lender used to determine that the structure was located in a SFHA. It is important to note that the LODR process does not consider the elevation of the structure or property above the flood level; rather, it considers only the location of the structure relative to the special flood hazard area boundary shown on the FIRM. Thus, property owners should be aware that the lender does not consider the elevation of the property or structure when determining if the property or structure is in or out of the SFHA. FEMA reviews this information and issues its finding of whether the structure is located in the SFHA according to the current NFIP map. The request for such a letter must be jointly requested by the property owner and the lender no later than 45 days following the date the lender notified the borrower that the property is in a special flood hazard area. While this determination cannot consider the elevation of the structure or property, it can be useful if the property owner feels the lender's interpretation of the map is incorrect.
To summarize, then, there are obviously some important distinctions between the two processes (LODR versus LOMA/ LOMR-F).
1. The determinations are based on different data. The LODR process does not consider the (vertical) elevation of the structure or property above the flood level; rather, it considers only the horizontal location of the structure relative to the special flood hazard area boundary shown on the Flood Insurance Rate Map. The LOMA/LOMR-F process uses actual survey elevation data to determine if the property or structure is at or above the elevation of the SFHA.
2. There are different fees involved. A listing of all fees associated with flood map reviews can be found on the FEMA website.
3. The determinations result in different actions. A LODR does not result in an amendment or revision to the National Flood Insurance Program map. It is only FEMA's finding regarding the structure's location with respect to a delineated special flood hazard area. A LOMA or LOMR-F actually removes the SFHA designation from the property by letter.
Fees associated with Flood Map Reviews