Changes to the NFIP

 

NFIP Flood Insurance Changes: October 2017, April 2018 and …January 2019

After the flurry of changes to the federal flood insurance program following the reform legislations of 2012 and 2014, FEMA has settled down on making changes in October, April and January.  In the recent October 2017 update, we saw minimal changes (HFIAA Surcharge can now be pro-rata refunded if a policy is canceled.  And except for mainly the Preferred Risk Policies, the Federal Policy Fee for contents-only policies was reduced to $25).  The latest version of the NFIP Manual includes these changes.

The recently announced changes for April 2018 and January 2019 (for the Preferred Risk Policy and Newly Mapped Procedure annual changes) are pretty much in line with last year.  

April 1, 2018 highlights:  Rate Increases:

  • Average premium increase is 6.9%
  • Besides the pre-FIRM subsidized premiums that are congressionally-mandated to increase 25% (e.g., non-primary residences, non-residential businesses), pre-FIRM premiums increase only 5%
  • Post-FIRM A Zones will see minimal to no increases; e.g., AE: 1%; AO or AH: 0%; Unnumbered Zone A: 2%
  • Standard X Zone: 1%

Primary Residence Determination: FEMA recognizes a policyholder can have more than one primary residence, as each spouse could live more than 50% of the year at a separate residence.

Phase 2 of Re-underwriting the NFIP policy base: This is delayed/extended.  In response to HFIAA, FEMA needs to send out letters to all policyholders to clearly communicate their risk.  To do so, FEMA asked insurance companies and NFIP-Direct to underwrite basically all renewal policies, but post-FIRM policies starting October 2016.  FEMA would then send a letter to each of those policyholders after the policy renewed.  The Post-FIRM phase was to start this October, but it is now delayed due to the recent hurricanes and will start when April 2018 renewal notices begin going out (though some companies have already started it).

January 1, 2019 changes:

  • Preferred Risk Policy (and eligible A99 and AR) premiums will increase 6%
  • The Newly Mapped policy multiplier continues to be 15%

NOTE: With all of that published, FEMA just released an additional Bulletin that increases the ICC premium starting April 1, 2018.  In some cases, the annual increase is $1, but in others, like pre-FIRM Zone A, we are seeing $5 and $10 increases.  FEMA did not revise the overall rate increase percentages mentioned above so we don’t know the relative percentage impact.

 

 NFIP Rate Changes Effective April 1, 2017

March 28, 2017

As announced on September 27, 2016, key changes being made to the National Flood Insurance Program (NFIP) on April 1, 2017, include updated insurance policy premium increases conforming to the premium rate caps established by the Biggert-Waters Flood Insurance Reform Act of 2012 (BW-12) and the Homeowners Flood Insurance Affordability Act of 2014 (HFIAA).

Premiums will increase upon renewal an average of 6.3 percent beginning April 1, 2017. Premiums do not include the HFIAA surcharge or the Federal Policy Fee (FPF), which are not increasing.

It is important to note that nearly 80 percent of NFIP policyholders are full-risk rated and therefore, minimally impacted by these rate increases. If individual policyholders have questions about their premiums, or NFIP coverage, we urge them to reach out to their insurance agent, or visit FEMA’s website, for more information.

More information on NFIP program changes taking effect April 1, 2017 is available here.

 

Collection: April 2017 NFIP Changes

April 12, 2017

This series of short videos explains some key elements of changes to the NFIP that are effective April 1, 2017.  Please see a brief explanation of each video segment below.

Collection Created:

Premium Increases and Surcharges:  This short video discusses the updated premium rates that conform to the premium rate caps established by Biggert-Waters and the Homeowner Flood Insurance Affordability Act.

Newly Mapped Multiplier Table:  This short video segment discusses changes related to the Newly Mapped Multiplier Table. In the April 2017 Program Changes, FEMA is providing updated multiplier tables to assist in determining  which multiplier to use in calculating the premium for properties newly mapped into a Special Flood Hazard Area through December 2018.

Substantially Improved Buildings and Updates to the Community Rating System List:  This short video discusses the clarifications for policy rating and loss adjustment for Pre-Flood Insurance Rate Map substantially improved properties and when the next update of the Community Rating System Eligible Community List will occur.

Videos by Amanda Bicknell

 

Specific Rating Guidelines – Effective April 2017

Specific Rating Guidelines – Effective April 2017.  This Specific Rating Guidelines manual provides the rules and rates for Submit-for-Rate risks.  These are properties at high flood risk that, because of peculiarities in their exposure to flooding, do not lend themselves to pre-programmed rates noted in the NFIP Flood Insurance Manual.  These risks require an in-depth underwriting analysis before a risk premium rate can be applied.

For a list of all Rate Changes, link to https://www.fema.gov/media-library/assets/documents/34620.

 

Annual Report of the Flood Insurance Advocate’s Office

February 28, 2017

FEMA released the second Annual Report of the Office of the Flood Insurance Advocate (OFIA).  Link to the Annual Report.

The OFIA identified six primary policyholder and property owner frustrations in 2016 that present opportunities for ongoing program improvement.  These issues are:

  1. erroneous Severe Repetitive Loss (SRL) property designations;
  2. gaps in flood insurance agent education;
  3. the need for consistency across FEMA Regions in public mapping outreach;
  4. difficulties in accessing Increased Cost of Compliance (ICC) coverage;
  5. difficulties with multiple and conflicting flood zone determinations; and
  6. inability to obtain a refund of the Homeowners Flood Insurance Affordability Act of 2014 (HFIAA) surcharge when cancelling a NFIP policy.

The issues identified in this report are based on the observations of OFIA through the hundreds of inquiries submitted to the Office this past year.  These issues represent areas of concern that have a long-term impact to a broad population of NFIP customers.  The Federal Insurance and Mitigation Administration’s (FIMA) program areas were provided an opportunity to respond to these findings and responses are included with this report.

NFIP Flood Insurance Advocate:  The OFIA advocates for the fair treatment of policyholders and property owners by providing education and guidance on all aspects of the NFIP, identifying trends affecting the public, and making recommendations for program improvements to FEMA leadership.  The OFIA is an independent office within FEMA with direct alignment to the FIMA Associate Administrator and the FEMA Administrator. 

For more information:  link to FEMA’s OFIA website.

 

2017 Flood Insurance Manual

Effective April 1, 2017

The NFIP Flood Insurance Manual is used primarily by insurers and agents selling and servicing Federal flood insurance.

Link to FEMA’s webpage for the latest manual and information.  

 

FEMA Bulletins

FEMA has issued a series of bulletins announcing rating, underwriting and processing changes. Here’s a quick glimpse into each along with a link to more reading material.

W-16018 – Deductible Disclosure and Cancellation Receipt Date Proceduresin the November  2015 edition of the NFIP Flood Insurance Manual (FIM), FEMA indicated that when a mortgagee was listed on an NFIP flood policy, the mortgagee’s written consent had to be secured before requesting a deductible higher than the applicable minimum deductible. That requirement has now been eliminated retroactive to November 1, 2015, since it is too burdensome to policyholders. Read more…

The same bulletin revises how cancellation effective dates that are based on the cancellation receipt date are determined. The November 2015 edition of the FIM stated that for the purpose of determining the receipt date of the cancellation/nullification request, the receipt date shall be that date on which the cancellation/nullification request, along with the complete supporting documentation for that request, is received by the insurer. That cancellation receipt date determination has now been revised. Read more…

W-16020 – April 2016 Revisions to the NFIP Flood Insurance Manual Posted Online – on March 29th an updated version to the NFIP Flood Insurance Manual was posted at: http://www.fema.gov/flood-insurance-manual .

W-16022 – October 1, 2016 Program Changes – FEMA provides a look ahead to program changes coming this autumn.  FEMA is implementing a number of changes to refund procedures that will better benefit policyholders. Some of the changes outlined are retroactive to a November 1, 2015, receipt date, but the effective date cannot be earlier than April 1, 2016.

Because the April 1, 2016, revisions to the FIM were already being finalized at the time of the preparation of this bulletin, the provisions of this bulletin supersede any conflicting guidance in the November 1, 2015, or April 1, 2016, FIM. Read more…

W-16024 – Implementation of Section 100214 of BW-12 – Payment of Condominium Claims – Section 100214 of Biggert-Waters prohibits FEMA from denying payment to condominium unit owners who purchased unit-owner building coverage under the Dwelling Form policy for building claims that cannot be paid by the Residential Condominium Building Association Policy (RCBAP). The RCBAP’s coinsurance penalty triggers when the building insurance coverage purchased by the condominium association is less than 80 percent of the full replacement cost of the RCBAP insured condominium building, or less than the maximum amount of insurance available. Read more…

 

Suggested Additional Reading – WYO Program Bulletins

FEMA periodically issues WYO Program Bulletins related to recent legislative changes and clarifications to the NFIP Flood Insurance Manual.  The bulletins are posted at http://www.nfipiservice.com/nfip_docs.html.

 

 

 

 

 

 

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