
The Quick Read: Usually, but only when the lender’s flood requirement rests on the federal flood map and the lender agrees to honor the letter. An LOMA removes the federal mandate; it does not bind a private DSCR lender, so the final call sits with the lender holding your file, and the letter must be delivered before anything changes. Think of the LOMA as strong evidence you hand to the lender, not a switch you flip.
- A LOMA corrects the map for your structure. It does not change the ground, the water, or your physical risk.
- Until the letter is issued, the existing flood requirement stands. A pending application earns you nothing at underwriting.
- A flood premium counts in the payment, so it lowers your DSCR. Rent is divided by the full monthly payment, flood insurance included.
- Delivery matters. The lender must receive the letter and update its own flood determination before dropping the requirement.
- Leverage caps, credit floors, and reserve rules do not move because of a LOMA. It only changes one line of the payment.
Key Terms Defined
Flood paperwork has its own vocabulary. Here are the terms this article leans on.
- LOMA (Letter of Map Amendment): A federal letter saying a structure on naturally high ground sits above the flood level, so the map was wrong for that structure.
- LOMR-F (Letter of Map Revision based on Fill): The same idea for land that was raised with fill dirt. It needs more documentation and has a fee.
- SFHA (Special Flood Hazard Area): The mapped zone where flood insurance is mandatory for loans from federally regulated lenders.
- BFE (base flood elevation): The mapped height floodwater is expected to reach in a major flood.
- Elevation Certificate: A form a licensed surveyor or engineer completes, showing your building’s height against the BFE. It is the supporting evidence for a LOMA, not a replacement for one.
- Flood zone determination: The lender’s own check, usually done by a third-party company, of whether the property sits in an SFHA.
- PITIA: Principal, interest, taxes, insurance, and any association dues. DSCR is rent divided by this figure.
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What Does a LOMA Change, and What Does It Leave Alone?
An LOMA changes one thing: how the flood map treats your structure. If the letter says your building’s lowest adjacent grade sits at or above the base flood elevation, the structure comes out of the high-risk zone on paper.
The water does not know about the paperwork. A building can be correctly removed from the mapped zone and still flood in a heavy storm. Keep that in mind when you decide whether to drop coverage later.
The letter also covers a structure, not necessarily a whole property. A floodplain-revisions explainer points out that an LOMA removes a structure rather than the land under it. Your lender should match the letter’s legal description to the collateral it is lending against. A mismatch is a common reason a lender hesitates.
A DSCR loan qualifies primarily on property-level rental income covering the payment, subject to lender guidelines. That is why a flood premium matters so much here. It sits inside the payment your rent has to cover.
Which Document Do You Actually Need?
Investors mix these up constantly. Each document does a different job, and only some of them can end a requirement.
| Document | What it is | Ends the requirement? |
|---|---|---|
| LOMA | Map fix for natural high ground | Yes, if lender accepts |
| LOMR-F | Map fix for fill-raised land | Yes, if lender accepts |
| Elevation Certificate | Surveyor’s height measurement | No, evidence only |
| Out as shown (LOMA-OAS) | Fix when only the lot, not the building, was flagged | Often, if lender accepts |
The out-as-shown path deserves a note. A municipal FEMA instruction sheet explains that some determination companies flag a property if any part of the lot touches the mapped zone, even when the building sits outside it. In that case, start by asking the lender what documentation it relied on. Clear visual evidence can sometimes settle it. Other times the lender will still want a federal letter.
Why Can a DSCR Lender Still Require Flood Insurance After a LOMA?
Because the mandate and the lender’s policy are two different things. FEMA states that an LOMA or LOMR-F eliminates the federal flood insurance purchase requirement tied to federal or federally backed financing. The same page says a lender keeps the prerogative to require flood insurance as a condition of financing, wherever the structure sits.
The federal bank regulators say the same thing from the lender’s side. The borrower must submit the LOMA to the lender before the requirement is waived, and the lender has discretion to keep requiring coverage. Only FEMA can issue a LOMA. Your surveyor cannot. Your lender cannot.
Now apply that to DSCR. Many DSCR lenders are private or non-bank, so the federal mandate may not bind them directly. Plenty still require flood coverage by their own policy or because of investor requirements. In practice, a DSCR lender’s flood rule is a risk overlay on its own paper. Some will accept an LOMA and drop the requirement. Others will accept it but ask for extra proof. A few will keep the requirement anyway.
That variation is the honest answer, and it is why the brokerage checks flood treatment early on a file, before you spend money on a survey. Across the wholesale network of lenders Lendmire works with, flood handling is not uniform, so a program that accepts an LOMA on one deal may want a fresh determination on another.
Do You Qualify for a LOMA? The Screening List
Run this list before you pay a surveyor.
1. Is the ground natural? A LOMA is for naturally high ground. If fill raised the land, you are in LOMR-F territory, which needs fill documentation: when it was placed, how much, and to what elevation. FEMA’s LOMA and LOMR-F page adds that a LOMR-F also needs the community to find the land reasonably safe from flooding.
2. Is the lowest adjacent grade at or above the BFE? That is the test. If it fails, no LOMA.
3. Is the building the problem, or the lot? If a determination flagged the lot only, the out-as-shown route may be shorter.
4. Does the letter match your collateral? The structure, the parcel, and the legal description should line up with the loan.
5. Who owns the property? The owner of record applies. If the rental sits in an LLC, the LLC is generally the owner and the applicant, subject to lender program eligibility.
Condos add a wrinkle. How an LOMA interacts with a building’s master policy is a lender-specific question, so ask before assuming anything.
The Process, Step by Step
Each party has a job. Here is the order.
1. The lender orders a flood determination. It is usually done by a third-party company and recorded on a standard form.
2. You hire a surveyor or engineer. They complete the Elevation Certificate. This is typically the real expense of the process.
3. You apply to FEMA. Paper forms or the Online LOMC application both work. Timing for FEMA’s determination varies by file, so check FEMA’s page for its current guidance on review timelines.
4. FEMA issues the letter, or denies it. Outcomes include full removal, partial removal, and denial.
5. You deliver the letter to the lender. A flood-services explainer says the letter must be in hand and delivered before the requirement lifts in practice. The lender then amends its determination and decides whether to drop its own policy requirement.
6. You deal with the insurer. Ask what the insurer needs from the lender to cancel, and check the policy’s cancellation terms. Do this before you assume a refund.
Skipping step 5 is the classic mistake. An approved letter sitting in your email does nothing for the lender’s file.
Timing: Before Contract, At Closing, or After
A 60-day federal review does not always fit a purchase contract. Here is how the three situations play out.
| Situation | What you do | What the lender likely wants |
|---|---|---|
| LOMA in hand before contract | Send it with the application | Letter plus updated determination |
| LOMA pending at closing | Bind flood coverage now | Policy in place at closing |
| LOMA obtained after closing | Send letter to lender | Review, then a decision |
There is no LOMA until FEMA issues it. A pending application, or a conditional letter reviewing a proposed project, does not change the map. Until the real letter exists, the current requirement stands, and your coverage ratio has to work with the flood premium included.
That last point is where files get tripped up. Plan the file so it qualifies with coverage in place. If the letter later removes the premium, that is a bonus, not a plan.
DSCR vs. conventional financing
There are two common ways to finance an investment property, and they qualify you differently — here’s how investors weigh them.
Why investors choose it
- Qualifies on the property’s rental income — no personal tax returns, W-2s, or pay stubs needed to document income.
- No personal debt-to-income ceiling to clear, so existing mortgages and obligations don’t cap your borrowing the same way.
- Can be closed in an LLC, keeping the property inside a business entity.
- Built for scaling — not held to the limit on number of financed properties that conventional financing applies.
- Underwriting centers on the deal: generally qualifies when the rent covers the payment, a 1.00x coverage ratio being a common baseline (confirmed in underwriting).
- Designed specifically for investment property, including long-term and, where the program allows, short-term rentals.
Where it’s strong
- Often the lowest ongoing financing cost for a buyer who fully qualifies on personal income — a fit for a first property or a cost-first purchase.
Trade-offs for investors
- Requires full personal income documentation and must fit within a debt-to-income limit — salary, existing debts, and other mortgages all count.
- Typically held in your personal name rather than a business entity.
- Caps how many financed properties you can carry, which can become a ceiling as a portfolio grows.
- Evaluates you as a borrower as much as the property, which usually means more paperwork.
How investors usually choose: a first or single property often optimizes for the lowest financing cost; portfolio builders often optimize for leverage, vesting in an LLC, and scaling past conventional caps. The right answer depends on your goals, the property, and current guidelines — both paths run through select lenders in Lendmire’s wholesale network, with eligibility and terms confirmed in underwriting.
What a Flood Premium Does to Your DSCR
Run the numbers on this modeled example. These are illustrative assumptions, not market data. Picture an investor under contract on a duplex that clears about 1.20x before any flood premium is counted. Add the premium to the payment, and the ratio slips to roughly 1.02x.
On paper, that file is still near 1.00, which is where many select programs start. But it is thin. A small change in insurance cost or rent can push it under. Coverage below 1.00 is available through select lenders in the network, with leverage and terms adjusted, so a file that slips is not automatically dead. It is a different conversation.
Two cautions. First, clearing 1.00 is not the same as positive cash flow. DSCR compares rent to the payment only. Repairs, vacancy, management, utilities, and capital expenses sit outside the calculation. Second, a larger down payment can lift the ratio by shrinking the payment, but it never erases leverage caps, credit floors, reserve rules, or property eligibility. Most purchases land at 75%–80% LTV on an investment property, and an LOMA does not change that. These specifics are subject to lender guidelines and a full review of property, leverage, and credit.
For the deeper mechanics, see Lendmire’s piece How to Keep Flood Insurance From Sinking an LLC DSCR Rental. If the property is near the water, the writeup on how a DSCR lender handles flood insurance on coastal rentals covers that case.
Is the LOMA Even Worth Chasing?
This one is a genuine toss-up, and it depends on the file. The stronger play depends on how much the premium matters to your ratio. If the property clears the lender’s coverage test comfortably with flood insurance, the survey and filing effort may not pay for itself. If the premium is the difference between a workable ratio and a weak one, the LOMA may be worth every dollar of the surveyor’s fee.
Weigh these factors:
- How much cushion do you have? A thin ratio makes the LOMA more valuable.
- How long will you hold? A long hold spreads the survey cost over more years of savings.
- Will the lender honor it? Ask first. A LOMA the lender ignores is wasted effort.
- Is the property truly above the BFE? If the surveyor’s numbers are close, expect friction.
When the Lender Says No
Sometimes the lender keeps the requirement. Sometimes FEMA denies the letter. You have options.
If the lender refuses a valid LOMA, ask what policy supports that and whether another program in the network treats flood differently. Programs vary. A different lender may take the same letter without a second look.
If FEMA denies the application, the likely reason is that the grade falls short of the BFE, or that fill raised the land. Fill-raised land points toward an LOMR-F, which carries more paperwork. If neither route works, you carry the coverage and underwrite the deal with the premium in the payment.
Should You Keep Coverage Anyway?
Often, yes. The flood-services explainer draws the line cleanly: an LOMA removes a purchase requirement, not the physical hazard. Flood damage to a rental means lost rent and repair bills, and standard property policies generally exclude flood. Dropping coverage after an LOMA is a legal choice, not necessarily a safe one.
Many investors keep a lower-cost voluntary policy on structures just outside the mapped zone. Tax treatment varies; consult a qualified professional.
Frequently Asked Questions
Does an LOMA automatically cancel my flood policy?
No. The borrower must submit the LOMA to the lender before any requirement is waived, and the lender keeps discretion to require coverage. After the lender accepts the letter, you still need to cancel the policy with the insurer and check its cancellation terms.
My DSCR loan isn’t federally backed. Do I need flood insurance at all?
If the property is in a mapped flood zone, expect to be asked for it. The federal mandate may not apply directly to a private lender, but many apply the same flood rules by policy. The requirement can come from the lender’s own risk rules or investor requirements, not only from federal law.
Can an Elevation Certificate alone remove the requirement?
No. It is evidence, not an amendment. It can support an LOMA application and may help a lender or insurer assess risk, but only FEMA can issue the letter that changes the map. The lender can still require coverage.
The determination flagged my lot, but the building is outside the zone. What now?
Start with the lender. Ask what documentation produced the flag. Clear visual evidence can sometimes resolve a wrong determination. If the lender still wants proof, the out-as-shown letter is the usual federal document.
What if my LOMA isn’t issued by closing?
Plan on binding flood coverage at closing and qualifying with the premium in the payment. Once the letter arrives, deliver it to the lender and ask about dropping the requirement. Check your loan documents and policy for cancellation terms before assuming anything.
Next Step
If you are buying or refinancing a rental property and want to see how the numbers work, Lendmire can help you compare DSCR loan options based on the property income, credit profile, leverage, and investor goals. As a broker with DSCR investor programs across 41 markets, including Washington, D.C., it can check how select lenders in the network treat flood requirements before you commit to a survey. For the fundamentals, start with the complete DSCR loans guide. Every file is underwritten individually, and nothing here is a commitment to lend.
Flood maps get redrawn, but the lender’s file is still decided on the day you apply, so the smartest move is to underwrite the deal with the premium included.
About Lendmire
A non-QM mortgage broker (NMLS# 2371349), Lendmire arranges DSCR financing for real estate investors in 41 markets — 40 states plus Washington, D.C. Because deals are underwritten primarily on property cash flow rather than personal income documentation, the structure suits self-employed buyers and entity-owned portfolios. Lendmire places loans through wholesale investor lenders; it is not a direct lender. Scotsman Guide named Lendmire a Top Mortgage Workplace in both 2025 and 2026.
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References
1. Floodzone-Revisions – Basics of LOMRs
2. Town of Alpine, Utah – FEMA Out-as-Shown Information
4. Sterling Flood – What Is an LOMA
This article is part of Lendmire’s DSCR loan program — full qualification details, guidelines, and scenarios live on the program page.
Related reading: How to Protect a DSCR Loan File With a Backup Lender · How to Shop and Document Rental Insurance Before a DSCR Loan · How to Document a Below-Market Lease for a DSCR Loan
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
- Mortgage Loan Originator · NMLS# 1129696 · Verify on NMLS Consumer Access
- North Carolina Real Estate Broker · License# 343312 · Verify on NCREC
- North Carolina Insurance Producer · License# 19053198 · Property, Casualty, Life, Health · Verify on NAIC SBS
- Lendmire LLC · Firm NMLS# 2371349 · Verify firm licensure
Required disclosures. Lendmire (NMLS# 2371349) operates as a licensed mortgage broker, not a direct lender or depository. The discussion in this article is general in nature and should not be relied upon as financial, legal, or tax advice — every investment scenario is unique and should be reviewed by a qualified professional. Any loan inquiry is subject to lender underwriting, and this article is not a commitment to lend or a guarantee of approval. Mortgage rates, loan terms, and program guidelines vary by borrower, property, and state, and may change without notice. Equal Housing Opportunity. Verify licensure at NMLS Consumer Access.