Federal Deposit
Insurance Corporation

From: Flynn, Traci
Sent: Monday, March 24, 2008 5:14 PM
To: Comments
Cc: Paul Matthews; Katie Spratling
Subject: RIN 3064-ZA00

To Whom It May Concern,

My question is regarding Section IV, #16 regarding loans secured by raw land.  The statute indicates that a loan secured by RAW land does not require flood insurance.  Concerning the definition of RAW land utilized in this instance – Does raw land mean any land without a structure or is there a differentiation between raw land and developed land that has no structure on it?  Specifically does a developed lot with no structure, which during the course of the loan will not have any structure on it, necessitate a flood determination as it is considered residential real estate?

Thank you,

Traci Flynn
Loan Review Supervisor