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This report studies the pricing of negatively elevated structures in the National Flood Insurance Program. Current NFIP methods for calculating risk-based premiums for these structures, including risk analysis, flood maps, and engineering data are examined. The report also evaluates alternative approaches for calculating risk-based premiums and discusses engineering hydrologic and property assessment data needs to implement full risk-based premiums. The findings and conclusions of this report will help to improve the accuracy and precision of loss estimates for negatively elevated structures, which in turn will increase the credibility, fairness, and transparency of premiums for policyholders.
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Consensus
·2015
Floods take a heavy toll on society, costing lives, damaging buildings and property, disrupting livelihoods, and sometimes necessitating federal disaster relief, which has risen to record levels in recent years. The National Flood Insurance Program (NFIP) was created in 1968 to reduce the flood risk...
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Description
Ad ad hoc committee will conduct a study of pricing negatively elevated structures in the National Flood Insurance Program. Specifically, the committee will:
· Review current NFIP methods for calculating risk-based premiums for negatively elevated structures, including risk analysis, flood maps, and engineering data.
· Evaluate alternative approaches for calculating “full risk-based premiums” for negatively elevated structures, considering current actuarial principles and standards.
· Discuss engineering, hydrologic, and property assessment data and analytical needs associated with fully implementing full risk-based premiums for negatively elevated structures.
· Discuss approaches for keeping these engineering, hydrologic, or property assessment data updated to maintain full risk-based rates for negatively elevated structures.
· Discuss feasibility, implementation, and cost of underwriting risk-based premiums for negatively-elevated structures, including a comparison of factors used to set risk-based premiums.
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Conflict of Interest Disclosure
Disclosure of Conflict of Interest: Lindene E. Patton
In accordance with Section 15 of the Federal Advisory Committee Act, the "Academy shall make its best efforts to ensure that no individual appointed to serve on [a] committee has a conflict of interest that is relevant to the functions to be performed, unless such conflict is promptly and publicly disclosed and the Academy determines that the conflict is unavoidable." A conflict of interest refers to an interest, ordinarily financial, of an individual that could be directly affected by the work of the committee. As specified in the Academy's policy and procedures (http://www.nationalacademies.org/coi/index.html), an objective determination is made for each provisionally appointed committee member whether or not a conflict of interest exists given the facts of the individual's financial and other interests and the task being undertaken by the committee. A determination of a conflict of interest for an individual is not an assessment of that individual's actual behavior or character or ability to act objectively despite the conflicting interest.
We have concluded that for this committee to accomplish the tasks for which it was established its membership must include among others, at least one person who has practical experience with and expertise in current methodologies that insurance companies use to assess risks associated with climate change.
To meet the need for this expertise and experience, Ms. Lindene Patton is proposed for appointment to the committee even though we have concluded that she has a conflict of interest because she is employed by a U.S. subsidiary of the Zurich Insurance Group, Ltd, which has U.S. subsidiaries that sell flood insurance whose financial interests could be affected by the outcome of the study. The U.S. subsidiary that employs Ms. Patton does not underwrite or administer National Flood Insurance Program policies.
As her biographical summary makes clear, Ms. Patton has developed expertise in insurance industry methods for assessing risks associated with climate change that are not currently accounted for in FEMA actuarial methods. Ms. Patton’s extensive experience in the insurance industry and her technical expertise related to climate change are critical to the ability of the committee to fulfill its task of examining alternative approaches for calculating full risk-based premiums. We believe that Ms. Patton can serve effectively as a member of the committee and that the committee can produce an objective report, taking into account the composition of the committee, the work to be performed, and the procedures to be followed in completing the work.
After an extensive search, we have been unable to find another individual with the equivalent experience and technical expertise as Ms. Patton who does not have a similar conflict of interest. Therefore, we have concluded that this potential conflict is unavoidable.
Disclosure of Conflict of Interest: Patricia Templeton-Jones
In accordance with Section 15 of the Federal Advisory Committee Act, the "Academy shall make its best efforts to ensure that no individual appointed to serve on [a] committee has a conflict of interest that is relevant to the functions to be performed, unless such conflict is promptly and publicly disclosed and the Academy determines that the conflict is unavoidable." A conflict of interest refers to an interest, ordinarily financial, of an individual that could be directly affected by the work of the committee. As specified in the Academy's policy and procedures (http://www.nationalacademies.org/coi/index.html), an objective determination is made for each provisionally appointed committee member whether or not a conflict of interest exists given the facts of the individual's financial and other interests and the task being undertaken by the committee. A determination of a conflict of interest for an individual is not an assessment of that individual's actual behavior or character or ability to act objectively despite the conflicting interest.
We have concluded that for this committee to accomplish the tasks for which it was established its membership must include among others, at least one person who has practical experience with and expertise in methodologies for calculating premiums for flood insurance policies within the National Flood Insurance Program (NFIP).
To meet the need for this expertise and experience, Ms. Templeton-Jones is proposed for appointment to the committee even though we have concluded that she has a conflict of interest because she is President of the Flood Insurance Servicing Companies Association of America and a senior executive at Wright National Flood Insurance Company, which sells flood insurance under the NFIP and whose financial interests could be affected by the outcome of the study.
As her biographical summary makes clear, Ms. Templeton-Jones has over 25 years of experience with the NFIP, including changes in policies and practices for writing and servicing flood insurance for the program. She also has substantial expertise in property and flood insurance underwriting, including measuring risk exposure and determining premiums. This past experience and her current expertise are critical to the ability of the committee to fulfill its task of reviewing NFIP methods for calculating premiums. We believe that Ms. Templeton-Jones can serve effectively as a member of the committee and that the committee can produce an objective report, taking into account the composition of the committee, the work to be performed, and the procedures to be followed in completing the work.
After an extensive search, we have been unable to find another individual with the equivalent experience and current technical expertise as Ms. Templeton-Jones who does not have a similar conflict of interest. Therefore, we have concluded that this potential conflict is unavoidable.
Sponsors
Federal Emergency Management Agency
Staff
Anne Linn
Lead