Re: Request for Extension of Comment Period, Federal Register Docket ID FEMA–2024–0004 Notice of Proposed Rulemaking
Dear Assistant Administrator Maurstad:
On behalf of organizations listed below, we respectfully submit this letter regarding the newly proposed flood policy form published in the Federal Register as a Notice of Proposed Rulemaking on February 5, 2024, Docket ID FEMA-2024-0004.
The proposed form is a positive and significant step forward to modernize not only the policy form itself, but what it covers and what it can cover, with the purchase of several optional endorsements for 1-4 family residential property owners.
Due to the extent and importance of the proposed changes to the dwelling form, it is imperative that all aspects and impacts related to these changes be thoroughly identified. To that end, the undersigned organizations feel that more time is required to ensure that the full breadth of the changes are understood, to avoid any unintentional consequences along with all the changes that each stakeholder will need to make in order to ensure success. While the proposed rules have been well laid out, we know that, for example, the policy wording development and review, the wording of the endorsements, and the rates will require deeper understanding, programming, and training at all levels and, will require significant time to implement. Impacted stakeholders will include groups such as agents, marketing and underwriting staff, vendors, lenders, lending regulators, claims adjusters, and probably others.
We are all working together to provide our input on the proposed rule, and would like to submit comprehensive comments that consider all of the above, and especially the impact on consumers. It will be extremely important that consumers understand the form differences and available options (for example, using the current dwelling form compared to the new policy form).
The NFIP's focus has been to provide the customer/policyholder with a positive experience and we want to support goal. Considering the work needed to make that happen, we believe that an extra 60-day period is essential (extending the comment period to 120 days total) to provide you with helpful and meaningful input.
As we've stated recently, your leadership has been instrumental in efforts to modernize the NFIP as well as work through legislative and regulatory issues including compliance with existing federal law.
Accordingly, we respectfully request an extension of the deadline to submit comments to June 7, 2024.
Respectfully submitted by the following organizations:
American Bankers Association (ABA)
American Property Casualty Insurance Association (APCIA)
Association of State Floodplain Managers (ASFPM)
Consumer Credit Industry Association (CCIA)
Flood Insurance Producers National Committee (FIPNC)
Independent Insurance Agents and Brokers of America (IIABA – "Big I")
National Association of Mortgage Brokers (NAMB)
National Association of Mutual Insurance Companies (NAMIC)
National Flood Association (NFA)
