Floodplain Information for Genoa Charter Township

In September of 2008, the Federal Emergency Management Agency completed their mapping of Livingston County floodplains. Genoa Charter Township has enacted a Floodplain Ordinance to protect those property owners who could potentially be affected by flooding. The FEMA Flood Insurance Rate Map Information is as follows:

Community number: 260843
Panel Number: 0330
Suffix: D

Residents who wish to determine if their property is within a FEMA mapped floodplain can view the Township floodplain map generated from FEMA data or view a list of properties sorted by parcel number.

FEMA and its National Flood Insurance Program (NFIP) partners are getting many calls and messages from flood insurance policy holders complaining about recent increases in their premiums; in many cases the premiums have increased dramatically. There are two principal reasons this may occur:

The first, and most typical, reason is a change in the mortgage lenders' internal lending policy, switching from requiring flood insurance only on the outstanding mortgage balance amount to actual cash value or replacement cost amount. Federally regulated and insured lenders are being encouraged to do this by their federal regulators (FDIC, Federal Reserve, Comptroller of the Currency, Fannie Mae, etc.), and FEMA supports this policy. However, it is not a FEMA rule or requirement. The law imposing the mandatory flood insurance requirement on federal mortgage lenders states that the amount of flood insurance must be the lesser of the outstanding loan balance, the maximum amount of flood insurance available, or full/replacement value. However, lenders have the right to impose higher amounts of flood insurance as a matter of sound lending practice, as stated in the mortgage casualty insurance clause in the lien. Your loan officer or mortgage lender insurance department should be able to explain this fully.

The second reason is a recent map change designating the insured building to be in a higher flood hazard risk zone. Greater risk exposure naturally means higher premiums. However, under certain situations, flood insurance costs can be "grandfathered" based on the previous risk zone allowing for substantial savings. Your insurance professional should be able to determine your eligibility to be "grandfathered."

Challenging your FEMA Floodplain Designation

There are many options for property owners who believe that they have been incorrectly mapped in the Special Flood Hazard Area (SFHA), but perhaps the most effective-and least utilized-is the LOMA-Out as Shown (LOMA-OAS).

Even though the Township has data that demonstrates that a property is out of the SFHA, many lenders will only accept official documents from FEMA for purposes of lifting the mandatory flood insurance purchase requirement. A traditional LOMA (form MT-EZ) is certainly an acceptable method, since it establishes the actual lowest adjacent grade around a structure and is certified by a Registered Land Surveyor.

For many properties, however, the time and expense involved with a traditional LOMA is not necessary. If the property owner or the community has reliable documentation clearly demonstrating that the structure (or building site) lies outside of the SFHA, the LOMA-OAS is in most cases the quickest and cheapest way to remove the mandatory purchase requirement. The LOMA-OAS is a document issued by FEMA that officially shows that a property and/or structure is not located in the SFHA. To obtain a LOMA-OAS, the applicant must submit mapping and survey data for the property, much of which is available from Genoa Township. Remember; only use this method if it is clear, visually, that the structure/building site is not in the SFHA.

Applying for a LOMA-OAS

To obtain a LOMA-OAS, the applicant must provide information to locate the property and/or structure on the FIRM. There is no fee for FEMA's review of a LOMA-OAS request, but the applicant is responsible for providing all of the information needed for FEMA's review. The following items should be submitted in support of all LOMA-OAS applications:

1. A copy of a recorded plat map for the property or a copy of the recorded deed for the property and a copy of the Genoa Township assessor's map of the neighborhood in question (or other map that shows property lines, local roads, and watercourses).
2. A completed MT-EZ application form with "out as shown" written at the top. This form is available on the FEMA website (https://www.fema.gov/media-library/assets/documents/8001). Write in "OAS" after the word LOMA in the fourth box down from the top. In the next box down, answer question 1 as "No." Under question 2 write "See Attached." Under question 3 check the third box "A structure on your property? What is the date of construction?" and write "N/A LOMA-OAS" at the end of the question. Fill out the last box on page one of Section A. Write "OAS" after "Structure located on natural grade (LOMA)." Write "OAS" after "Legally recorded parcel of land or portion thereof (LOMA)." Fill out the rest of the form as appropriate.
3. A FIRMette, created at http://www.msc.fema.gov. For information on how to create one, click on "FIRMette Tutorial" at the bottom of the screen.

The issuance of a LOMA-OAS eliminates the federal flood insurance purchase REQUIREMENT as a condition of obtaining federal or federally backed financing. However, the mortgage lender retains the prerogative to require flood insurance as a condition of providing financing, regardless of the location of the structure. The property owner also needs to be reminded that there is still a risk of the property's being flooded; it has been just reduced, NOT REMOVED. If you have questions about the use of the LOMA-OAS form, you can call 1-800-FEMAMAP (877-336-2627).