(November 15, 2013) --
The Honorable Craig Fugate
Administrator
Federal Emergency Management Agency
500 C Street, SW
Washington, DC 20472
Dear Administrator Fugate:
The undersigned organizations representing the impacted real estate, development, finance and insurance industries and local governments, urge you to convene a National Flood Insurance Summit immediately to bring greater certainty to many of the provisions currently being implemented in the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert Waters Act).
The housing markets are still recovering in a fragile economy. In the more than 20,000 communities nationwide where flood insurance is required to secure a mortgage, we are responding to several difficult implementation decisions made by the Federal Emergency Management Agency (FEMA) involving the Biggert Waters Act. We understand FEMA has a monumental task, implementing this complex and far-reaching law. However, uncertainty and confusion surrounding these implementation issues are now beginning to stall transactions nationwide. We believe this summit should be separate from legislative efforts, and should focus on the provisions of the reform act that require immediate attention and clarification.
The impacted stakeholders are on the front lines working directly with borrowers, home owners and businesses. Our roles in real estate transactions require us to explain the law and respond to any questions or misconceptions that may arise. It is vital we better understand FEMA’s intentions and approach to the law so we can educate the public and convey critical information about the law’s implementation. We have many questions about FEMA’s plans, timelines and challenges, and we need up-to-date and accurate data.
We propose the following topics to begin the discussion. These are all subjects we believe have administrative flexibility and where the industry can work with you to provide greater certainty in implementation. These include:
Expediting regulations for the reimbursement of flood mapping appeals, the Technical Mapping Advisory Council, and installment payments to improve the affordability of flood insurance;
Working to streamline and better publicize the Community Rating System (CRS) so the program is used by more communities to lower premiums;
Streamlining and better educating consumers about the process for obtaining Elevation Certificates;
Developing better education and information resources for the real estate, lender, development and insurance industries and local governments, including information about reducing premiums by mitigation actions;
Enhancing consumer education and materials on the impacts of the Biggert Waters Act and the ongoing flood mapping process, including materials on the scientific resolution panel review process for map appeals; and,
Designating a FEMA "Ombudsman" or a consumer point-of-contact for implementation and mapping issues and concerns.
The undersigned organizations support a fully authorized, sustainable, and fiscally responsible National Flood Insurance Program (NFIP). We have a vested interest in the most efficient, effective implementation of the new law, and we believe a National Summit with the key stakeholders will begin discussing a way forward. Thank you.
Sincerely,
American Bankers Association
American Bankers Insurance Association
Association of State Flood Plain Managers
Credit Union National Association
Independent Community Bankers of America
Independent Insurance Agents & Brokers of America, Inc
Manufactured Housing Institute
Mortgage Bankers Association
National Apartment Association
National Association of Counties
National Association of Federal Credit Unions
National Association of Home Builders
National Association of Local Housing Finance Agencies
National Association of Realtors
National Flood Determination Association
National Multi Housing Council