Sens. Cassidy, Booker Request Information from NFIP Stakeholders
Senator Cassidy and Senator Cory Booker (D-NJ) solicited information from NFIP stakeholders through a Request for Information (RFI), due on September 15. The RFI sought input on reauthorization, affordability, mitigation, Risk Rating 2.0, transparency, and other topics. Responses will be shared with Senate Banking Committee and used to inform a reintroduced version of the NFIP Reauthorization and Reform (NFIP-RE) Act.
Many CSFI partners and members responded to the RFI. We thank our partners for lending their expertise and their time in composing responses. Responses from the American Bankers Association (ABA), National Flood Association (NFA), National Association of Insurance Commissions (NAIC), and NAR can be viewed online.
All RFI questions are pertinent to CSFI’s interests, including:
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Should a reauthorized NFIP continue to exist within FEMA, or should it belong to another agency, like HUD or the Federal Housing Finance Agency (“FHFA”)?
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How should an affordability program be designed? Who should be eligible for premium discounts? Should eligibility be based on the area median income (AMI), federal poverty level (FPL), mitigation efforts, community-level mitigation, other assessments / ratios, or a combination?
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Are there new data sources or technologies that should be considered when modifying or replacing Risk Rating 2.0?
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How could the Risk Rating 2.0 methodology be changed or replaced to more accurately reflect a property’s true risk rating and past mitigation efforts? What aspects of the legacy flood insurance premium rating system are superior to Risk Rating 2.0?
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What other mitigation measures lower flood risk and should be considered in the premium methodology? What mitigation measures lower flood risk in dense urban areas? Should the Risk Rating 2.0 methodology and its data sources receive a third-party review for reasonableness and consistency? If so, how should this review be conducted, and who should be involved in this review? Should FEMA publicize Risk Rating 2.0 data, methodologies, and risk modeling for public access?
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What steps could FEMA and / or Congress take to improve transparency in NFIP rate-setting, claims processing, or program administration?