Recommendation: The Director of the Federal Insurance Office should publicly communicate information about when it is considering certifying an event as an act of terrorism under TRIA. (Recommendation 1)

Agency: Department of the Treasury: Office of the Under Secretary for Domestic Finance: Office of the Assistant Secretary for Financial Institutions: Office of Financial Institutions Policy: Federal Insurance Office
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Federal Insurance Office should document an agreement with DHS about DHS's role, and how the agencies share information, during the process of certifying an event as an act of terrorism under TRIA. (Recommendation 2)

Agency: Department of the Treasury: Office of the Under Secretary for Domestic Finance: Office of the Assistant Secretary for Financial Institutions: Office of Financial Institutions Policy: Federal Insurance Office
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Federal Insurance Office should document an agreement with DOJ about DOJ's role, and how the agencies share information, during the process of certifying an event as an act of terrorism under TRIA. (Recommendation 3)

Agency: Department of the Treasury: Office of the Under Secretary for Domestic Finance: Office of the Assistant Secretary for Financial Institutions: Office of Financial Institutions Policy: Federal Insurance Office
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: To help ensure that the government is not exposed to more liability risk than intended, the Secretary of Transportation should ensure that the FAA Administrator prioritizes the development of a plan to address the identified weakness in the cost-of-casualty amount, including setting time frames for action, and update the amount based on current information.

Agency: Department of Transportation
Status: Open

Comments: The Department of Transportation agreed with the recommendation. In March 2018, the Federal Aviation Administration (FAA) stated that the agency planned to conduct a rulemaking to address any updates to the cost-of-casualty amount. As part of the rulemaking, FAA planned to engage with the commercial space and insurance industries to obtain views on an appropriate cost-of-casualty amount and implications of any changes. However, in February 2019, FAA stated that it has been unable to conduct the planned rulemaking due to a competing priority that will continue through 2020. FAA has requested input from the industry on prioritizing needed rule revisions and will develop a plan for updating the cost-of-casualty amount based on the industry's prioritization recommendations. We will continue to monitor FAA's actions in response to this recommendation.

Recommendation: To promote forward-looking construction and rebuilding efforts while FEMA phases out most subsidies, the Secretary of the Department of Homeland Security should direct FEMA to consider amending NFIP minimum standards for floodplain management to incorporate, as appropriate, forward-looking standards, similar to the minimum standard adopted by the Hurricane Sandy Rebuilding Task Force.

Agency: Department of Homeland Security
Status: Open

Comments: In August 2019, a FEMA official stated that FEMA intends to implement the recommendation in full eventually, but it is unlikely that it will happen as a cohesive effort in 2020, given other ongoing flood insurance reforms. As of August 2020, the status of this recommendation remains unchanged.

Recommendation: To establish full-risk rates for properties with previously subsidized rates that reflect their risk for flooding, the Secretary of the Department of Homeland Security (DHS) should direct the FEMA Administrator to develop and implement a plan, including a timeline, to obtain needed elevation information as soon as practicable.

Agency: Department of Homeland Security
Status: Open
Priority recommendation

Comments: As of January 2020, FEMA continues its multi-year effort to redesign its risk rating system to reflect industry best practices, such as providing credible, understandable rates based on graduated risk. As part of this redesign, FEMA plans to obtain multiple sources of data and information about a property's risk of flooding--from which it may be able to derive elevation information on some properties--to develop the insurance rate. FEMA has delayed implementation of the new risk rating system until 2021, pending further analysis. In addition, FEMA issued a Request for Information on obtaining structural elevation information from third party sources and is reviewing responses from potential vendors. The agency also encourages subsidized policyholders who seek to ensure the appropriateness of their NFIP rates to voluntarily submit elevation documentation. We will continue to monitor the extent to which FEMA is able to produce elevation information for all currently subsidized properties.

Recommendation: The Secretary of the Department of Homeland Security should direct FEMA to take steps to ensure that its rate-setting methods and the data it uses to set rates result in full-risk premiums rates that accurately reflect the risk of losses from flooding. These steps should include, for example, verifying the accuracy of flood probabilities, damage estimates, and flood maps; ensuring that the effects of long-term planned and ongoing development, as well as climate change, are reflected in the flood probabilities used; and reevaluating the practice of aggregating risks across zones.

Agency: Department of Homeland Security
Status: Open
Priority recommendation

Comments: In April 2018, FEMA officials told us they had begun to redesign NFIP's risk rating system to help ensure policy rates better reflect the risk of flooding. The redesign, known as Risk Rating 2.0, includes efforts to use catastrophe models, stochastic approaches, and updated map information to better reflect the variation in flood risk. These reforms are also intended to improve how FEMA's rating process accounts for general and specific factors that affect flood probabilities and damage. While FEMA initially announced that new rates for all single-family homes would go into effect nationwide on October 1, 2020, it announced in November 2019 that it would defer implementation to October 1, 2021. FEMA said this would allow it to conduct a comprehensive analysis of the proposed rating structure so as to protect policyholders and minimize any unintentional negative effects of the transition, and that the new implementation date would cover all NFIP policies.

Recommendation: The Secretary of the Department of Homeland Security should direct FEMA to ensure that information is collected on the location, number, and losses associated with existing and newly created grandfathered properties in NFIP and to analyze the financial impact of these properties on the flood insurance program.

Agency: Department of Homeland Security
Status: Open

Comments: As of February 2020, FEMA officials said they had finished identifying properties with grandfathered premium rates and that they planned to analyze their economic implications as part of their efforts to update their premium rate setting approach, known as Risk Rating 2.0. FEMA plans to implement this redesign on October 1, 2021.