CSFI Submits Public Comments for FEMA Review Council Final Report
The FEMA Review Council released its Final Report on May 7, 2026, and public comments were due on Monday, June 8. The full meeting recording and the presentation provided at the Review Council’s final meeting can be reviewed online.
In the report, Key Recommendation #7 aims to “Reform the FEMA National Flood Insurance Program (NFIP) for Financial Stability and Risk Resilience.” Specific sub-recommendations include “Modernize Risk Assessment (Update Risk Rating 2.0 & Improve Maps),” “Revise ‘Write Your Own’ Compensation,” “Shift to Private Market through Depopulation of Existing NFIP Policies,” and “Address Repetitive Loss Properties.”
In response to the report, CSFI has prepared and submitted a public comment, underscoring our perennial NFIP policy priorities and offering the Commission on Natural Disaster Risk and Insurance Act as a next step in assessing “methods to promote the take-up of flood insurance policies” and the overall Federal role in insurance.
In response to specific sub-recommendations in the report, CSFI offers suggestions, summarized below:
- Empower Communities (Better Land-Use Policies): FEMA should more closely collaborate with land use planners and floodplain managers at the community level, both individually and through national groups like the Association of State Floodplain Managers (ASFPM).
- Modernize Risk Assessment (Update Risk Rating 2.0 & Improve Maps): There is no clear process to update or rectify Risk Rating 2.0, its rating factors, and its data inputs. States, communities, and entities such as levee districts should have a pathway for involvement.
- Implement Risk-Based Pricing & Actual Costs: Risk Rating 2.0 was self-certified by the consultant and has never undergone a third-party review. CSFI urges a formal peer review of the Risk Rating 2.0 methodology and an analysis of its impacts.
- Revise ‘Write Your Own’ Compensation: Given NFIP’s vulnerable policies in force and total written premium volume, reducing the expense allowance at this time may not be opportune nor reflective of agents’ critical role in the program.
- Shift to Private Market through Depopulation of Existing NFIP Policies: Depopulating the NFIP will create a more concentrated risk pool, increasing Average Annual Loss rate and while reducing premiums collected.
- Evaluate Development of Flood Insurance Marketplace. Instead of centralized clearinghouse for a national market exchange, FEMA should work with the private sector and third-party data providers to develop a clearinghouse for rating factors and mitigation measures.
- Address Repetitive Loss Properties: In order to address RLPs, NFIP should be granted forbearance on debt service payments ($626M in FY27) and be required to deposit savings into the National Flood Mitigation Fund.
- Reduce Duplicative ESA Burden on the NFIP: The current exposure to ESA lawsuits limits NFIP’s administrative capacity and prevents focus on the program’s purposes.