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Big ‘I’ Submits Comments on FEMA’s Direct to Customer Initiative

The comments express concern for the proposal and detail the vital role that agents play in the sale and servicing of National Flood Insurance Program (NFIP) policies.
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big ‘i’ submits comments on fema’s direct to customer initiative

In July, FEMA released a new, concerning proposal for the National Flood Insurance Program (NFIP) called Direct to Customer (D2C).

The initiative was unveiled in a request for information (RFI), which was released to a suite of potential vendors on a General Services Administration (GSA) schedule. The RFI gave a brief overview of the D2C initiative and asked questions about how FEMA should approach developing and delivering the initiative. 

In the RFI, FEMA noted that “other lines of insurance have made the leap into the digital realm, including WYO companies for their other lines of insurance. Flood Insurance remains behind the times, leading to potential customer frustration and the inability to protect one's home or business."

“As FEMA strives to increase climate resilience, ensure equitable access and outcomes for all citizens, and promote and sustain a ready FEMA and nation, it is imperative that FEMA enable the digital sale and servicing of flood insurance to increase the number of people covered. FEMA calls this initiative 'Direct to Customer' or 'D2C,'" FEMA said.

In response to the RFI, the Big “I" submitted three sets of comments last week. The Big “I" submitted one set of comments as part of the Flood Insurance Producer National Committee (FIPNC), a second set of comments as part of a coalition with the American Property Casualty Insurance Association, and a third set of comments from the Big “I."

The comments express concern with the release of the proposal and detail the vital role that agents currently play in the sale and servicing of NFIP policies. The comments also note that there must always be an important role for agents in the NFIP. Although the RFI says comments were due on Aug. 4, the deadline was extended until Aug. 26.

Additionally, at the end of July, Chris Heidrick, chair of the Big “I" Flood Subcommittee; Joe Rossi, incoming chair of the Big “I" Flood Subcommittee; and other Big “I" staff met with FEMA as part of the FIPNC to express concern with the proposal and the future role of independent agents in the D2C effort.

During the discussion, FEMA noted that this is a long-term—2-4 years—project and that they are in the early stages of looking at the concept and beginning to ask questions about it.

Wyatt Stewart is Big “I" assistant vice president of federal government affairs.