What should our HOA board do when a new FEMA flood map changes our community's flood zone?

By OurHOA · General information · Revised October 20, 2026

What an HOA board does when FEMA issues a new flood map: the 90-day appeal, LOMAs for common buildings, flood insurance, lender letters and what to tell owners.

Part of the HOA board handbook: vendors, projects and upkeep.

The short answer

Treat the preliminary map as a project with a deadline, because it has one. Once FEMA publishes the proposed map, owners and the association get one 90-day window to appeal it, and FEMA says that window cannot be extended. After it closes and appeals are resolved, FEMA sends the city or county a Letter of Final Determination, and the new map takes effect six months later. In that time the board should find out which lots and association buildings changed zones, decide whether an engineer's appeal is worth paying for, order elevation certificates for association buildings newly shown in a high-risk zone, get flood insurance quotes, and tell owners what changed. This guide is general education, not legal advice. Your declaration decides who insures which buildings, and state and local floodplain rules vary.

Find out what changed and when the clock starts

FEMA sends preliminary flood maps, called Flood Insurance Rate Maps or FIRMs, to the community, which is your city or county, not your association. The preliminary maps and the current maps are both posted on FEMA's Map Service Center at msc.fema.gov, and FEMA's Flood Map Changes Viewer shows where zones moved. Pull both versions for every panel that covers your community and mark lots that moved into a Special Flood Hazard Area (zones beginning with A or V), lots that moved out, and any association building that changed zones. FEMA publishes a proposed notice in the Federal Register and announces the 90-day appeal period in a local newspaper, printed twice. Under 44 CFR 67.5, the 90 days run from the second newspaper printing. Ask your local floodplain administrator for the start and end dates in writing and put the end date on the board calendar.

Appeal or comment, and when an appeal is worth it

An appeal objects to a change in base flood elevations, flood zone boundaries, zone designations or the floodway, and it must come with data showing the new information is scientifically or technically incorrect. That usually means a licensed engineer's hydrology or hydraulic analysis. A comment covers everything else, such as a misnamed road. Both go in writing to the community's chief executive or the official it names, not straight to FEMA. Under 44 CFR 67.5, any owner or lessee of property in the community may appeal, so the association can appeal as owner of its common area. FEMA's guidance for property owners says that because of map scale, requests about individual lots or structures usually cannot be resolved through the appeal. Those go through the Letter of Map Amendment process below. An appeal makes sense when the board has reason to think the study itself is wrong, for example a drainage channel or detention pond built after the survey data was collected. An appellant unhappy with FEMA's final decision may appeal to federal district court within 60 days of receiving the Letter of Final Determination.

Letters of Map Amendment for association buildings

A Letter of Map Amendment, or LOMA, is FEMA's official finding that a building or parcel shown in a high-risk zone actually sits on natural ground above the base flood elevation. FEMA charges no review fee for a LOMA. The cost is a licensed land surveyor or registered professional engineer, who prepares an Elevation Certificate. FEMA says it confirms within 30 days whether the request is complete and issues a decision within 60 days of receiving all the required data. If the ground was raised with fill, the request is a LOMR-F instead, and FEMA charges a fee for those. For association buildings, the association applies as the owner. FEMA's MT-EZ form covers a single lot or structure; the MT-1 package and the Online LOMC application cover multiple lots or structures. One surveyor visit can measure the clubhouse, the pool house and every owner who wants in. Make it an offer, not a requirement, and have each owner file their own request. If owners already hold LOMAs, check them. When new map panels take effect, FEMA issues a revalidation letter listing the earlier LOMAs that remain valid. One missing from that list may have been superseded and may need a new request. A LOMA removes the federal requirement to buy flood insurance, but FEMA notes the mortgage lender keeps the right to require it anyway.

Flood insurance on association buildings

Start with the declaration. In a condominium, the association usually insures the buildings, and the National Flood Insurance Program sells it a Residential Condominium Building Association Policy, with building coverage of up to $250,000 times the number of units. FEMA pays building losses under that policy at replacement cost, with a co-insurance penalty if the building is insured for less than 80 percent of its replacement cost, so ask the agent to check the limit against a current replacement cost figure. In a single-family HOA, owners insure their own homes, and the association's exposure is its common buildings. A clubhouse or pool house is a non-residential building, and NFIP coverage for those, under the General Property form, runs up to $500,000 for the building and $500,000 for contents, and each policy covers one building. Two FEMA facts change the timing. First, under the current rating system a zone change does not by itself change the premium, because FEMA no longer uses zones and base flood elevations directly as rating variables. A clubhouse in Zone X is worth pricing either way. Second, a building moved from Zone B, C or X into a high-risk zone may qualify for the Newly Mapped discount: 70 percent off the premium on the first $35,000 of building coverage and $10,000 of contents, for a policy bought or renewed within 12 months after the map update, with the premium then rising no more than 18 percent a year. Get quotes before the effective date and calendar the 12-month window.

Lender letters and what to tell owners

Owners with a federally backed or federally regulated mortgage on a building newly placed in a Special Flood Hazard Area will hear from their lender. Under 42 U.S.C. 4012a(e), when a lender finds the property is not covered, it must notify the borrower, and if the borrower does not buy the required coverage within 45 days, the lender must buy it and may charge the borrower for it. Send owners a short notice as soon as the preliminary map is out. Sample wording: "FEMA has released new preliminary flood maps for our area. Under these maps, [number] homes in our community, listed on the attached page, would move into a high-risk flood zone, and [number] would move out. The maps are not final. The public appeal period ends [date], and the new maps are expected to take effect around [date]. If your home moves into a high-risk zone and you have a mortgage, your lender will likely require flood insurance. Policies bought or renewed within 12 months after the map changes may qualify for a discount. The board is [appealing / not appealing] and is arranging a group survey for owners who want to apply for a Letter of Map Amendment. Reply by [date] to join." Our guide on whether an HOA can require flood insurance explains the owner side of these rules.

State rules in Texas, Florida and Colorado

Sellers have to talk about flood risk in both Texas and Florida. Texas Property Code section 5.008 requires the seller's disclosure notice for a single-dwelling residential sale to say whether the property is wholly or partly in a 100-year floodplain, which the notice defines as a Special Flood Hazard Area shown on the flood insurance rate map, and whether it is in a 500-year floodplain or a floodway. Florida Statutes section 689.302, added in 2024 and amended in 2025, requires sellers of residential property to give a flood disclosure at or before signing the contract, covering known flood damage during their ownership, flood insurance claims and flood assistance, including from FEMA. Colorado adds a building rule. Colorado Water Conservation Board rules, 2 CCR 408-1, effective January 14, 2022, set a minimum of one foot of freeboard above the base flood elevation: new, substantially damaged or substantially improved residential buildings must have the lowest floor at least one foot above it, and non-residential buildings may instead be floodproofed to that height. A remapped clubhouse that needs a major rebuild will have to meet it, so note that in the reserve study. Local ordinances in all three states can go further, so ask the floodplain administrator what applies.

A sample timeline

Week 1 after the preliminary maps appear: one director lists changed lots and buildings and gets the appeal dates. Week 2: notice to owners. Week 3: the board decides on an engineer and gets a surveyor's quote. Day 60: any appeal package goes to the community official, leaving it time to forward the package before day 90. Letter of Final Determination: the board confirms the effective date and gets insurance quotes. Effective date: buy coverage on any association building that needs it, file LOMA requests against the new map, and check the revalidation letter. Twelve months after the effective date: the Newly Mapped discount window closes.

Mistakes boards make

Waiting for a mailed notice that never comes, then learning about the map from an owner's lender letter after the appeal window has closed. Filing an appeal about one house's elevation, which FEMA will route to the LOMA process anyway. Assuming the clubhouse is fine because its zone did not change. Telling owners the map is final when it is still preliminary. If a storm does reach the buildings, our guide on how to handle an HOA insurance claim after a storm covers the claim itself.

Sources

These guides are general education for HOA boards and residents, not legal, tax, or financial advice. Rules vary by state and by your community's governing documents - check with a professional for your situation.

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