ASFPM CFM common mistakes
ASFPM CFM · Understand the traps and how to avoid them.
Reads the Elevation Certificate and takes the elevation from the wrong line - using Item C2 (BFE) as if it were the structure's elevation, or treating 'lowest adjacent grade' as the lowest floor - and then signs off on a lowest-floor determination built on that number.
The form is dense and the field names look interchangeable under time pressure; candidates who have never filled one out live default to the first elevation-looking number they see.
What to do instead
Memorize the handful of lines that drive decisions: C2 (BFE), the lowest-floor lines under Section C for each building diagram, and Section E/A for grade. Before answering, say out loud which line you are reading and what it represents; on a real permit, the as-built EC must be checked line by line against the approved site plan.
Determines that every 'A' zone has a published base flood elevation and writes a permit condition of 'lowest floor at or above the BFE' for a property in an unnumbered A zone, or the reverse - tells the applicant there is no floodplain requirement because no BFE appears on the map.
The candidate remembers the general rule (elevate to the BFE) but not the exception for approximate/unstudied A zones, and the map legend is easy to skim.
What to do instead
Before setting any elevation requirement, confirm which A-zone subcategory applies. In unnumbered A zones with no BFE, the community must still require elevation - obtain or require best available data, and absent a BFE, the practical floor is the highest adjacent grade (many communities add freeboard on top). 'No BFE' never means 'no requirement.'
Runs the substantial improvement calculation as improvement cost divided by an assessed value that includes the land (or divided by the recent purchase price, or by the value after the work), or evaluates each permit in isolation rather than cumulatively.
Whatever number is on the property record card is the easiest to grab, and each permit file feels self-contained when it crosses the counter.
What to do instead
Use the market value of the structure only, exclusive of land, determined before the improvement. Track improvement costs cumulatively over a defined window (commonly a rolling five years) rather than per permit, and use the same discipline for substantial damage (damage cost vs. pre-damage structure value) so both tests point the same direction.
Approves dry floodproofing (or a wet-floodproofed lower level) for a one- or two-family dwelling, or allows a 'walkout' or sunken room to escape the definition of basement and be counted as above the BFE.
Floodproofing sounds like an equivalent technical solution, and 'basement' is assumed to mean a hole dug under the house rather than any floor below grade on all sides.
What to do instead
Anchor two rules: residential structures must be elevated - floodproofing is a non-residential option only, with a floodproofing certificate; and a basement is any floor whose top is below ground level on all sides, which captures walkouts and sunken rooms. When in doubt, the floor counts as the lowest floor.
Tells an applicant that a LOMA will lower the BFE or remove a filled lot from the Special Flood Hazard Area, or advises a LOMR when only an administrative LOMA is needed - mixing up LOMA, LOMR, LOMR-F, and CLOMR.
The acronyms differ by one letter and all sound like 'get the map changed'; the distinctions are about natural grade vs. fill and about whether a physical or regulatory change is being made.
What to do instead
Sort by one question - is the ground natural or filled, and is construction already done? Structure on natural high ground, no fill: LOMA. Fill involved: LOMR-F. Construction not yet built: CLOMR first. Only a LOMR can revise a BFE or floodway. A LOMA is administrative and never moves the BFE.
Reverses the Community Rating System scale - assumes a Class 1 community gets the smallest discount, or a Class 10 the largest - or assumes CRS participation waives the mandatory purchase requirement.
Most rating scales elsewhere put '1' at the bottom, and CRS discounts feel like a separate insurance regime rather than a credit on the same policy.
What to do instead
Memorize the direction: Class 1 is the best (45 percent discount on SFHA premiums), Class 9 is the weakest credit (5 percent), Class 10 is no discount and no participation. CRS changes premium cost only; it never changes who is required to buy.
Classifies a building as pre-FIRM because the original structure predates the map, even though it has just been substantially improved or substantially damaged - and therefore quotes or accepts subsidized pre-FIRM rating.
The 'date built' field is what people look at, and the substantial improvement determination happens in a different office from the insurance question.
What to do instead
Treat substantial improvement or substantial damage as a rating reset: once the threshold is crossed, the building is rated as post-FIRM and the subsidized pre-FIRM treatment ends. Always ask two questions - when was it built relative to the effective FIRM (or Dec. 31, 1974 for initial maps), and has it been substantially improved or damaged since?
Advises a property owner that insurance is legally required for any building inside the SFHA, or that a mapping change alone triggers a purchase obligation.
'Mandatory purchase' is a phrase candidates learn early and apply too broadly, without the federal-lender link.
What to do instead
State the trigger precisely: the requirement attaches to buildings securing loans from federally regulated or insured lenders, or federal agency loans and grants - not to location in the SFHA by itself. Unmortgaged or conventionally financed buildings in the SFHA may buy, but are not compelled to.
Treats 'No Adverse Impact' as the regulatory floor the community must meet, or uses it interchangeably with the no-rise certification required for floodway encroachments.
Both phrases are about not harming neighbors, and both appear in the same training material, so they blur into one idea.
What to do instead
Separate the two: no-rise is a specific regulatory test tied to floodway encroachment - a registered engineer's certification that the encroachment will not increase flood levels, and the permit cannot issue without it. No Adverse Impact is a broader, beyond-minimum management philosophy covering the whole watershed and cumulative effects. One is a permit gate; the other is a policy posture.
Issues the development permit when the plans show a compliant lowest floor, then closes the permit and issues the certificate of occupancy without ever requiring or reviewing the finished-construction Elevation Certificate.
The plan-review step feels like the decision point, and the as-built step gets lost when the file is handed off or the project runs long.
What to do instead
Make the as-built EC a written condition of the permit and a hard prerequisite for the certificate of occupancy. If the as-built lowest floor is lower than approved, the file reopens as a violation - the compliance date is the as-built elevation, not the drawing.