Use a FEMA Letter of Determination Review (LODR) when you and your lender believe the lender’s flood-zone determination placed the building on the wrong side of the Special Flood Hazard Area boundary shown on the current effective FEMA map. The lender and borrower must request the review jointly, and the request must be postmarked within 45 days of the lender’s notice. FEMA reviews the building’s map location—not its elevation.
If your argument depends on natural ground elevation, an Elevation Certificate, or changing the map designation itself, an LODR is usually the wrong route. That is the key distinction to settle before you spend time assembling documents.
Use an LODR only for a lender’s map-location decision
The FEMA LODR fact sheet describes the process as a review of a lender’s determination that a building is in a Special Flood Hazard Area (SFHA). FEMA compares the location of the building with the SFHA shown on the applicable effective Flood Insurance Rate Map (FIRM). The review does not redraw the map, certify the property as flood-free, or estimate an insurance premium.
A useful first question is therefore: “Do the lender and borrower dispute where the building sits on the effective map?” If the answer is no, stop and identify the actual issue before treating LODR as a general flood-zone appeal.
LODR and LOMA solve different problems
The names are similar, but the evidence and result are different. Choosing the wrong process can waste a short filing window.
| Question | LODR | LOMA |
|---|---|---|
| What is disputed? | Whether the lender correctly located the building relative to the SFHA on the effective FIRM | Whether naturally high ground or other qualifying map evidence supports removing a structure or land from the mapped SFHA |
| Who requests it? | Borrower and lender jointly | The property owner or authorized applicant through the applicable Letter of Map Change process |
| Main evidence | Lender notice, SFHDF, technical determination data, and an effective map panel showing the building | Property, survey, elevation, deed, subdivision, and other evidence required for the selected application |
| Does FEMA consider elevation? | No | Elevation or natural-ground evidence may be central, depending on the request |
| Does it amend the map? | No; it reviews the lender’s determination | A favorable letter documents a FEMA map determination for the property or structure |
For the map-change route, use the LOMA and LOMR-F guide and FEMA’s Change Your Flood Zone page. Do not attach an Elevation Certificate to an LODR expecting FEMA to weigh the building height; the governing regulation expressly excludes elevation data from this review.
The 45-day clock starts with the lender’s notice
The current 44 CFR § 65.17 says the joint request must be submitted within 45 days of the lender notifying the borrower that the building or manufactured home is in an SFHA and flood insurance is required. The regulation further says the review request must be postmarked within that 45-day period.
Record the date on the lender’s notice as soon as you receive it. Ask the lender which date it treats as the notification date, calculate the deadline conservatively, and leave time for the lender’s signature and the complete supporting package. Do not assume that calling the lender, ordering a survey, or starting a different FEMA application pauses the LODR deadline.
If more than 45 days have already passed, FEMA’s response options under the regulation include returning the materials without review. Discuss the determination with the lender and determine whether a different correction or map-change process fits the evidence.
Ask the lender for the determination and its source material
The FDIC Flood Disaster Protection Act examination manual explains the role of the Standard Flood Hazard Determination Form (SFHDF) in a lender’s decision. It also notes that, for an LODR, the lender would need to make the determination available to the borrower. Ask for a complete, legible copy rather than relying only on a loan-portal message that says insurance is required.
- the lender’s written notice stating that the building is in an SFHA and flood insurance is required
- the completed SFHDF used for the determination
- the map panel, effective date, and other technical data the determination provider relied on
- the lender contact who can review and sign the joint request
- the exact building the determination covers when the parcel contains more than one structure
Check that the street address, community, parcel context, building footprint, and map panel all refer to the same property. A correct panel with the pin placed on a detached garage, vacant part of the parcel, or neighboring structure can create a different dispute from a genuinely outdated panel.
Build the joint request FEMA can review
Section 65.17 lists the materials required for FEMA’s review. Use the regulation and the current FEMA fact sheet as the final checklist on the day you assemble the package; forms, fees, and delivery instructions can change.
- The required review fee. The FEMA fact sheet checked for this article states a current cost of $80; verify the amount and payment instructions again before sending.
- A written request for review signed by both the borrower and the lender.
- A copy of the lender’s notice that the building or manufactured home is in an SFHA and flood insurance is required.
- A completed SFHDF plus a legible hard copy of all technical data used to make the determination.
- A copy of the effective FHBM or FIRM panel with the building location marked. The submitted portion must retain the panel title block, effective date, bar scale, and north arrow.
The regulation specifies payment by check or money order in U.S. funds payable to the National Flood Insurance Program. Follow the newer FEMA fact sheet if it supplies updated mailing or payment instructions, and retain proof of the version you used. Do not send original survey or property documents unless the current instructions specifically require them.
Use the FIRM panel guide to verify the panel number, effective date, scale, north arrow, and title block. If the lender relied on a preliminary map while the regulation calls for the effective map, compare their roles with the preliminary-versus-effective map guide.
Why an Elevation Certificate is outside this review
An LODR asks a horizontal location question: is the building footprint inside or outside the SFHA boundary on the effective map? It does not ask whether the first floor sits above the Base Flood Elevation or whether the natural ground qualifies for a map amendment. Section 65.17 states that elevation data will not be considered.
That rule is easy to miss because elevation evidence can be important in other FEMA and insurance workflows. Keep the documents, but route them to the process that can actually consider them. The Elevation Certificate source guide explains why the correct recipient depends on whether the certificate was requested for a permit, policy, lender, or map-change application.
What happens while FEMA reviews the package
FEMA states that it will make a determination within 45 days after receiving all necessary data. That is a response period after a complete submittal; it is not an automatic pause on loan closing, insurance, escrow, or a lender’s compliance duties.
The FEMA fact sheet says that if the loan closes before the review period ends, flood insurance is required. Keep the required coverage in force unless the lender and insurer give you written instructions based on the completed review. Stopping or delaying coverage on your own can create a lapse without changing the lender’s determination.
Read the response before changing insurance
Under § 65.17, FEMA may respond in one of three ways:
- The request was submitted more than 45 days after notification, so no review will be performed and the materials are returned.
- The package lacks enough information; the lender’s determination stands until a complete submittal is received.
- FEMA completes the review and states whether the building or manufactured home is within the SFHA.
A completed result identifies the NFIP community, property or building, map panel and effective date, whether the structure is in the SFHA, and the period during which the determination is effective. Compare every identifier with the lender’s original notice before asking the lender or insurer to change the loan file or policy.
A favorable result may not end every insurance requirement
FEMA’s fact sheet explains that a successful LODR can release the lender from the federal statutory obligation to require flood insurance. The lender may still require flood insurance under its own risk and safety-and-soundness practices. The letter also does not say the building cannot flood or calculate a new premium.
The fact sheet says a refund for the current policy term may be available if the review finds the structure outside the SFHA, the lender waives the purchase requirement, and no claim has been made. That is conditional language, not an automatic refund. Ask the lender and insurer what written documents they require before canceling or changing coverage.
The FEMA map versus Risk Rating 2.0 guide explains why a mandatory-purchase decision and an NFIP premium are related but separate questions.
If the map or building placement still appears wrong
Open the current effective panel through the FEMA Map Service Center, confirm the community and effective date, and compare the building footprint—not just the parcel outline—with the mapped boundary. Check for effective Letters of Map Change and later panels. A consumer map pin, tax parcel layer, or real-estate listing is not a substitute for the determination materials FEMA requires.
If the disagreement is based on natural ground or surveyed elevation, move to the appropriate LOMA or other Letter of Map Change path. If the building was simply plotted incorrectly on the lender’s technical data, work with the lender on the joint LODR package while the 45-day window is still open.
Keep a complete record after you send it
- the lender’s notice and the date you received it
- the signed joint request and every attachment
- the fee amount, payment record, delivery address, and current FEMA instructions used
- the carrier, tracking number, and postmark or acceptance date
- requests for missing information and the date you answered them
- FEMA’s final letter and all lender and insurer responses
Keep the package together with the loan and property records. A later refinance, sale, map update, or insurance review may involve a different effective map or a new determination.
Questions borrowers still have
Can I request an LODR without the lender?
No. The regulation requires the borrower and lender to submit the request jointly, and both must sign the request. Ask the lender who is authorized to coordinate and sign it.
Can an Elevation Certificate prove the lender is wrong?
Not in the LODR process. FEMA does not consider elevation data under § 65.17. Elevation may be relevant to a LOMA, floodplain-management, or insurance workflow, but those are separate decisions.
Does an LODR change the FEMA map?
No. It reviews whether the lender’s determination correctly locates the building relative to the SFHA on the effective map. Use a Letter of Map Change process when the requested outcome is a FEMA map determination based on qualifying property evidence.
Should I cancel flood insurance as soon as I submit?
No. Submission does not suspend the lender’s requirement or guarantee a favorable result. Keep the required coverage until the review is complete and the lender and insurer provide written instructions.
What if the 45-day deadline has passed?
FEMA may return a late LODR request without review. Ask the lender whether the technical determination can be corrected and determine whether a LOMA or another map-change route fits the actual evidence.
The FEMA fact sheet, 44 CFR § 65.17, and the FDIC examination manual were checked on July 28, 2026. Recheck the current FEMA fee and delivery instructions before mailing. FloodMapCheck provides source routing and interpretation; it does not represent FEMA, a lender, an insurer, or a legal adviser.
Use the next official workflow
- How to Read Your Lender’s Standard Flood Hazard Determination Form — Before deciding whether an LODR fits, read the lender's Standard Flood Hazard Determination Form and verify the building, panel, date, zone and LOMC fields.
- How to Appeal a Preliminary FEMA Flood Map During the 90-Day Period — If the disputed information is on a proposed communitywide map, use the preliminary FEMA map appeal process instead of an LODR.
Related insurance and compliance checks
- Newly Mapped Into a FEMA High-Risk Flood Zone: Insurance and Lender Steps — A new effective map can trigger a lender determination and a separate insurer review of Newly Mapped eligibility.