Changes Coming to the National Flood Insurance Program What to Expect Impact of changes to the NFIP under Section 205 of the Biggert-Waters Act

Transcription

1 Changes Coming to the National Flood Insurance Program What to Expect Impact of changes to the NFIP under Section 205 of the Biggert-Waters Act Joe Cecil, Federal Insurance and Mitigation Administration

2 Changes are Coming to the NFIP Congress passed the Flood Insurance Reform Act of 2012 (Biggert Waters 2012), which will: Make the NFIP more financially stable by raising rates on certain classes of property to reflect true flood risk; and Trigger rate changes for certain properties within a revised or updated map area to accurately reflect the flood risk. 2

3 Changes are Coming to the NFIP, cont d The changes will mean rate increases for many policyholders over time. Buying or selling a property, or allowing a policy to lapse may trigger rate changes. There are investments you and your community can make to reduce the impact of rate changes. 3

4 History of the NFIP 1968: Congress created the NFIP to make affordable flood insurance generally available (flood damage is not covered by most homeowners insurance policies)and to decrease Federal disaster assistance expenditures. To participate, communities adopt and enforce floodplain management measures for all new development. For structures built before FEMA mapped the Special Flood Hazard Area (SFHA) (called pre-firm properties), the NFIP made flood insurance available at subsidized rates that did not reflect the true risk of flooding. 4

5 Why the Changes to the NFIP? 45 years later: Flood risks continue, and the costs and consequences of flooding are increasing. Artificially low rates and discounts no longer are sustainable. In 2012, Congress passed legislation to make the program more sustainable and financially sound over the long term. 5

6 What is Changing? Flood insurance rates Rates for most properties will more accurately reflect risk. Subsidized rates for non-primary residences are being phased out now. Other subsidized rates will be eliminated over time: New policies sold after July 6, 2012 to cover previously uninsured properties; and Purchase of a property, allowing a policy to lapse, repetitive loss or cumulative damage, or other events, could trigger rate changes beginning in When a community adopts a new flood map, discounts like grandfathering will be phased out meaning premiums will increase over time. Expected in

7 What is Changing? Cont d Flood risks and the costs of flooding Weather patterns, erosion, and development are a few factors increasing flood risk in many communities. Better science, improved tools and more data are providing more accurate definition of flood hazards. More buildings and other infrastructure are being built in areas at risk for flooding and replacement costs continue to grow. 7

8 When Will Changes Occur? Now Changes underway: Full-risk rates will apply to property not previously insured, newly purchased, or to a policy which is repurchased after a lapse. Premiums for older (pre-firm) non-primary residences in a Special Flood Hazard Area will increase by 25 percent each year until they reflect the fullrisk rate began January 1,

9 When Will Changes Occur? October 1,2013: Premiums for pre-firm business properties, severe repetitive loss properties (1-4 residences), and properties where claims payments exceed fair market value will increase by 25 percent each year until they reflect the full-risk rate. Normal rate revisions which occur annually, and increases will include a 5% assessment to build a catastrophic reserve fund. 9

10 When Will Changes Occur? Late 2014: Premiums for properties affected by map changes will increase over five years at a rate of 20 percent per year to reach full-risk rates. 10

11 Who Will Be Affected by Subsidy Changes? Not everyone only 20% of NFIP policies receive subsidies and an even smaller number will see immediate changes. Owners of subsidized non-primary residences in a Special Flood Hazard Area will see 25% increase annually until rates reflect true risk began January 1, Owners of subsidized property that has experienced severe repetitive flood losses or that has incurred flood cumulative damage with flood insurance payments exceeding the value of the structure will see 25% rate increase annually until rates reflect true risk beginning late Owners of subsidized business properties in a Special Flood Hazard Area will see 25% rate increase annually until rates reflect true risk -- beginning late Owners of substantially damaged or substantially improved subsidized property will see 25% rate increase. 11

12 What are the Subsidized Rates Impacted by Section of BW 12? Subsidized premiums are estimated at a rate that is less than sufficient to fund the reserves for anticipated losses and expenses that will occur within the subsidized rate classes. Section (205) of BW 12 eliminates only the subsidy to Pre-FIRM rates for properties in certain SFHA s without elevation data from an Elevation Certificate (EC) for Flood Insurance, and Pre-FIRM zone D properties. Full-risk premiums are estimated at a rate sufficient to fund the reserves for anticipated losses and expenses that will occur within each class. Post-FIRM standard X-zone, D-zone, PRP s and the PRP s issued under the Eligibility Extension and most policies using Post-FIRM elevation rating tables are not subsidized even if under the NFIP Grandfather procedures. The NFIP establishes rate classes by zone, and Post-FIRM rates for all zone classes are not impacted by Section of BW

13 How Are Full-Risk (Actuarial) Rates Determined? Elevation rating: the science behind the rates RATE Max = i=min ( PELV DELV ) i i LADJ DED UINS EXLOSS PELV is the probability that flood waters reach a certain depth (frequency) DELV is the ratio of the flood damage to the value of the insurable properties (severity) LADJ, DED, UINS Loss adjustment expenses, underinsurance, and deductible EXLOSS is the loading for expenses and contingency Tom Hayes, ACAS & Andy Neal, FSA CAS 2012 In Focus Seminar: Taming Cats October

14 Policyholder Subsidies These policies are not Pre-FIRM subsidized (already actuarially rated), 4,480,669 policies. They are not affected by 205 but may see routine annual rate increases. NFIP Policyholders under Section 205 (data as of 12/31/2012) 81% 5% 10% 4% These pre-firm nonprimary residences, business properties, and Severe Repetitive Loss (SRL) properties (252,851 policies) will see 25% increases until the true risk premium is reached. These pre-firm primary residences (578,312 policies) will retain their subsidies until sold to new owner, policy lapse, etc. These properties, which include pre-firm condos and multifamily properties (244,085 policies) will not see immediate subsidy removal. 14

15 Policyholder Subsidies, cont d 15

16 Policyholder Subsidies, cont d 16

17 How are subsidies eliminated? Phase-out at 25% annual premium increase for policies insured prior to the Act. Immediate application of full-risk premiums for those insured after the Act. Do not confuse with elimination of grandfathering triggered by a map change to be implemented in

18 Changes for Non-Primary Residences Rates will increase up to 25 percent per year until they reflect the fullrisk rate Changes become effective January 1, 2013, for new/renewal policies Pre-FIRM: Built before the community s first Flood Insurance Rate Map became effective and not substantially damaged or improved since then Non-primary residence: A building that will be lived in by the homeowner or the owner s spouse for less than 80 percent of the year 18

19 Changes for Business Properties Premiums for pre-firm business properties will increase by 25 percent each year until they reflect the full-risk rate. New applications will identify business properties separate from other nonresidential buildings. Business properties will be rated as non-residential until the rulemaking process is complete. For application purposes, a business property is any non residential building that produces income, or a building designed for use as office or retail space, or for wholesale, hospitality or similar uses. 19

20 Changes to Other Subsidized Rates Premiums for pre-firm commercial buildings Increase by up to 25 percent per year until they reach full-risk rates Premiums for repetitively flooded buildings These Severe Repetitive Loss properties of one to four residences will receive a premium increase of up to 25 percent per year until reaching full-risk rates Includes buildings with cumulative flood insurance claim payments that meet or exceed fair market value These changes will start in late

21 Direct Move to Full-Risk Rates After the purchase of a property Subsidized rates cannot be assigned to the new owner After a policy lapse Allowing a policy to lapse could be costly When a new policy is issued Policies for buildings uninsured as of the date that the law was passed (July 6, 2012) If an offer to mitigate has been refused Changes slated to begin in October

22 New and Lapsed Pre-FIRM Policies Full-risk rates will apply immediately to property not previously insured, newly purchased, or with a lapsed policy, or when an owner refuses an offer to mitigate, on or after July 6, 2012 An Elevation Certificate, including photos, must be obtained within 1 year to determine full-risk rating. Tentative or Provisional rates can be used for up to 1 year Properties will be rated using post-firm procedures. Buildings with enclosures below the BFE will be rated as non-elevated buildings 22

23 Who Won t Be Affected by Subsidy Changes? Owners of primary residences in SFHAs will be able to keep their subsidized rates unless or until: You sell your property (new rates will be charged to next owner if they insure;) You allow your policy to lapse; You suffer severe, repeated flood losses; or You purchase a new policy (after July 6, 2012). 23

24 Reserve Fund The legislation requires establishment of a reserve fund to pay for future losses In addition to rate increases accounting for true and changing risk, a 5 percent premium increase will go toward the reserve fund Exception: Preferred Risk Policies and Group Flood Insurance Policies 24

25 Reserve Fund, cont d Overall, premiums will increase an average of 10 percent in beginning in late 2013 Pre-FIRM premium increases related to the phase out of subsidies and discounts include a 5 percent increase for the reserve fund For example: A policyholder for a pre-firm, non-primary residence will pay a rate increase of 20 percent and 5 percent for the reserve fund for a total premium increase of 25 percent 25

26 What about when a new flood map is adopted? If you live in a community which adopts a new, updated Flood Insurance Rate Map (FIRM) : Charging of insurance premiums based on a prior FIRM -- grandfathering -- will be phased out. The Biggert-Waters Act Section calls for a phase-out of grandfathering discounts for properties shown on Flood Insurance Rate Maps that are updated. But the pain is lessened somewhat, because new rates will be gradually phased in at 20% per year for five years Implementation anticipated in

27 PRP Eligibility Extension Changes Premiums will increase for properties insured by the Preferred Risk Policy (PRP) Eligibility Extension, which allows structures mapped into a high-risk area to remain insured at lower PRP rates. Premiums for properties mapped into Special Flood Hazard Areas (SFHAs) on or after Oct. 1, 2008, and receiving the PRP Eligibility Extension will see average annual increases of 20 percent starting late

28 What Will Happen to Grandfathering? There is no change to the built-in-compliance Grandfather procedure at this time (year 2013). This includes the small set Pre-FIRM buildings constructed prior to January 1, 1975, but after the initial FIRM date. All other Pre-FIRM buildings never qualified for this procedure. The continuous coverage Grandfather procedure is unchanged, with one exception: When a subsidized policy is assigned to a new owner due to a purchase, the policy must be full-risk rated according to the current FIRM. Policies reinstated after a lapse in coverage have always lost their eligibility for the continuous coverage Grandfather procedures. However, such policies also lose eligibility to use subsidized rates. Grandfathering and the Preferred Risk Eligibility Extension will be changed or replaced when Section is implemented in The Act calls for a transition to current risk rates over 5 years in 20% increments. 28

29 What Can I Do to Lower Costs? Home and business owners: Talk to your insurance agent about your insurance options You ll probably need an Elevation Certificate to determine your correct rate Higher deductibles might lower your premium Consider remodeling or rebuilding Building or rebuilding higher will lower your risk and could reduce your premium Consider adding vents to your foundation or using breakaway walls Talk with local officials about community-wide mitigation steps 29

30 What Can We Do to Lower Costs? Community leaders: Consider joining the Community Rating System (CRS) or increasing your CRS activities to lower premiums for residents. Talk to your state about grants. FEMA issues grants to states which can distribute the funds to communities to help with mitigation and rebuilding. 30

31 Saving Money on Flood Insurance FEMA has programs to help owners reduce their risk and save money on flood insurance. Community-wide discounts through the Community Rating System (CRS). FEMA grant programs to support communities rebuilding and relocating structures after a flood. Use of higher deductibles to lower premium costs but talk to your agent about your situation first. The smartest way to save might be to build higher. 31

32 Biggert-Waters and Rebuilding Decisions After a Flood As elevations go up, premiums can drop. ZONE A EXAMPLE Homes built below BFE could be hit hard by an increase to full-risk rates Elevating 3 feet above the BFE could lower premiums significantly! 32

33 Biggert-Waters and Rebuilding Decisions After A Flood Future insurance savings can offset higher construction costs. ZONE V EXAMPLE ( NEW BFE SHOWS 4 HIGHER RISK) 33

34 Flood Insurance and mitigation Flood insurance is one way of reducing risk and making communities more sustainable and resilient The NFIP provides Federally backed flood insurance that allows communities, homeowners, and business owners to protect their financial investments. But, insurance alone is not enough Without taking action to mitigate against future events, we jeopardize our safety, our financial security, and our self-reliance Just as communities make changes so that they are stronger and more flood resilient, Congress has also made changes to the NFIP so that it can be stronger and more sustainable in the future 34

35 The Bottom Line Many changes are coming to the Flood Insurance program Congress acted to make program stronger financially On many more policies, flood insurance rates will reflect full risk. Insurance rates will rise on some policies There are specific actions which will trigger rate changes Talk to your insurance agent about how changes may affect your property and flood insurance policy Building or rebuilding higher can lower your flood risk and could save you money FEMA can help communities lower flood risk and flood insurance premiums through: CRS program Various mitigation grants Technical advice on building and rebuilding to mitigate future flood damage 35

36 Resources FEMA.gov/BW12 FloodSmart.gov Realtor.org Coming Soon Fact sheets, Bulletins, brochures, and more. Flood insurance basics, Map Update Toolkit, Flood Map Update Schedule Field Guide to Flood Insurance, BW- 12 articles with new information and resources Co-branded fact sheets and passalongs, webinars and information sessions 36