From:
Dan Coons [mailto:dcoons@mabank.com]
Sent: Monday, April 19, 2004 3:28 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov; Barbara Wilson; Brian Winter; Brock Legan; Rusty
Neill; Scott Nelson
Subject: EGRPRA
To Regulators
dealing with burdensome regulations,
These comments
deal with "Loans in Identified Flood Hazard Areas, 12 CFR
208.25 Reg H.
Our bank is in
a rural area. Flood insurance is available only in incorporated
areas of our home county. Flood hazard determinations are required
though on all parcels of land which have a "structure" as
defined in the regulation. That includes a grain bin or even an
old barn which is beginning to fall over. If our customers in the
unincorporated areas had flood insurance available to them, then
the reg would make more sense. Even if flood insurance were available,
it would seem wasteful to require a flood insurance determination
on a dilapidated building which adds no economic value to the property.
With flood insurance unavailable, it seems very wasteful of time,
money and effort to require the flood hazard determination.
While I realize
it is only $18.00 to have a flood certification done, it is not
as simple as just fill in the request and it is back. In these
rural areas an address has not been assigned to every parcel which
has a "structure" but does not have a residence. Therefore,
when our loan assistants request a flood cert, they must first
try to determine what the address is for the property in question.
Then it becomes an issue for each customer who owns such a property
that they must pay $18.00 for something which is totally valueless
to them. On one occassion, I had a customer who built a house on
a 40 acre tract. That tract was in an unincorporated area and yet
did have a flood zone on the 40 acres. The flood zone happened
to be at the very west end of the property and he had built on
the middle of the property. His house was probably 40 or 50 feet
higher than the flood zone (please understand that I am not a surveyor,
but he built high on the hill and nowhere near a level which would
be endangered by a flood. Not even in the floods we experienced
in 1993 and 1995 was this property remotely threatened). Yet we
had to do a flood determination and then he had to have a flood
survey done. All of this inspite of the fact that he could not
buy flood insurance protection because it was not available in
his unincorporated area.
Please review
the regulations and consider the issue of flood determinations
on all structures, even in areas where flood insurance is unavailable.
Thank you,
Dan Coons, a
rural Missouri banker
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