Changes to the NFIP

 

Annual Update: National Flood Insurance Program Rate Changes Effective April 1, 2019

October 1, 2018

As announced on Oct. 1, 2018, key changes being made to the National Flood Insurance Program (NFIP) on April 1, 2019, 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 Homeowner Flood Insurance Affordability Act of 2014 (HFIAA).

  • Premiums will increase upon renewal an average of 8.2 percent beginning April 1, 2019.  These amounts do not include the HFIAA Surcharge, or the Federal Policy Fee (FPF).  It is important to note that nearly 80 percent of NFIP policyholders already pay a full-risk rate. 
  • Annual premium increases of 5 percent for Preferred Risk Policies (PRPs) and 15 percent for Newly Mapped procedure policies will become effective Jan. 1, 2020.

Effective April 1, 2019, FEMA will introduce a Severe Repetitive Loss (SRL) Premium for all policies covering properties with an SRL designation.  The SRL Premium will be 5 percent for all SRL policies.  Link to the April 1, 2019, and January 1, 2020, Program Changes.

 

Congressional Research Service Takes a Deep Look into Private Flood Insurance & the NFIP

July 2018

The report describes the current role of private insurers in U.S. flood insurance, and discusses barriers to expanding private sector involvement.  The report considers potential effects of increased private sector involvement in the U.S. flood market, both for the NFIP and for consumers.  Finally, the report outlines the pro-visions relevant to private flood insurance in the House and Senate NFIP reauthorization bills.  Read the full report here.

 

FEMA Releases Affordability Framework for the National Flood Insurance Program

April 17, 2018

FEMA released an Affordability Framework for the NFIP, which for the first time provides data-driven analysis of the cost burden borne by flood insurance policyholders and potential policyholders, identifies the populations most burdened by the cost of flood insurance, and provides options for policymakers to consider to help close the flood insurance gap across the nation by reducing the cost burden of flood insurance.

Through the Biggert-Waters Flood Insurance Reform Act of 2012 and the Homeowner Flood Insurance Affordability Act of 2014, Congress directed FEMA to examine options to aid individuals so they could afford risk-based premiums under the National Flood Insurance Program (NFIP), and to develop a framework to help policymakers consider how to provide targeted assistance to policyholders and potential policyholders.

In the Affordability Framework, FEMA proposes several options based on income and offers descriptive models of the cost of each option.  The following tasks were considered:

  • – Understand the affordability of the current NFIP portfolio as a baseline to better understand the impact of changes going forward.
  • – Begin the process of building the affordability framework.
  • – Complete the process of building an affordability framework.

As part of FEMA’s 2018-2022 Strategic Plan, FEMA is working to close the insurance gap with the assistance of both public and private insurers.  As the largest provider of flood insurance in the United States, the NFIP is working to double the number of properties covered by flood insurance from the current 4 million to 8 million by 2023.

The Affordability Framework is available online at www.FEMA.gov/national-flood-insurance-program-publications.

 

FEMA Announces the Release of the Annual Report of the Flood Insurance Advocate

April 6, 2018

FEMA released the 2017 Annual Report of the Office of the Flood Insurance Advocate (OFIA).  The report is intended to increase transparency, and to support the ongoing improvements to the NFIP with the goal of reducing its complexity.  A copy of the Annual Report and Summary can be found on FEMA’s website at www.fema.gov/national-flood-insurance-program-flood-insurance-advocate.  Or link to the Annual Report Executive Summary.  

In 2017, the OFIA identified eight primary policyholder and property owner challenges, which include recommendations that present opportunities for reducing the complexity of FEMA:

  • Challenges to customer communication during the claims process
  • Effectiveness of map change communications
  • Misunderstandings regarding Zone A
  • Lack of premium reduction following a lower-level abandonment of a building
  • Basement determination made at the time of loss
  • Lack of refunds for duplicate coverage with private insurance
  • Severe repetitive loss mitigation
  • Lenders requiring coverage where a claim would not be paid

New to this year’s report is the identification of two external trends (affordability and the complexity of the NFIP) that may require legislative or funding action solutions to resolve.  The issues identified in this report are based on the observations of the roughly 500 inquiries the Office received, about 25 percent more than last year’s total.

 

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.

 

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

 

 

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-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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