We know many National Flood Insurance Program (NFIP) agents have concerns about shepherding their clients through the transition to Risk Rating 2.0 (RR 2.0). As part of our effort to disseminate information about RR 2.0 to our agents, PIA will be using this space to share information about RR 2.0 and upcoming trainings provided by the Federal Emergency Management Agency (FEMA).  

Please note: The information contained below is current as of the date posted. Some aspects of the transition are still being finalized. As always, we will provide PIA members with new information as it becomes available, but your first step should be to contact your Write-Your-Own (WYO) carrier for the most relevant, up-to-date information.

Timeline

Here are some important dates to keep in mind:

September 1, 2021: FEMA will distribute final versions of the Industry Transition Memo (ITM), Flood Insurance Manual (FIM), and FIM appendices. (Draft versions of each are available here, here, and here, respectively.) Also on this date, all agents are expected to gain access to the RR 2.0 rating engine through their WYO and/or vendor.

October 1, 2021: Risk Rating 2.0 rates will be applicable to all new policies. Existing policies with renewal dates between Oct. 1, 2021 and March 31, 2022 will be eligible for renewal using a RR 2.0 rate if that rate is lower than a property’s “legacy” rate. Existing policies with renewal dates between Oct. 1 and March 31 will be renewed using legacy rates if legacy rates are lower.

From October 1, 2021-April 1, 2022: The legacy rating system and RR 2.0 will coexist, and properties subject to renewal during this time will be renewed at the more favorable of the two rates.

April 1, 2022: All remaining policies will transition to RR 2.0, and the legacy rating system will no longer be available.

October 1, 2022: From this point forward, all policies previously renewed using the legacy system will be renewed using RR 2.0.

Renewals Eligible for Early Transition

Agents need to know how much of their flood book will be affected by the fact that policies renewing between Oct. 1 and Apr. 1 may be eligible for early transition to RR 2.0 rates.

FEMA has distributed this National Rate Analysis bar chart to demonstrate the approximate policy breakdown. Approximately 23 percent of current policyholders are expected to experience a premium decrease. Of those, FEMA expects slightly fewer than half, or 11.5 percent of current policyholders, to be subject to renewal at RR 2.0 rates between Oct. 1 and Apr. 1.

Comparison of Applicable Rating Factors

One of the most significant differences between the current system and RR 2.0 is that RR 2.0 will consider several rating factors that are not part of the legacy rating system.

The legacy system takes into account the following variables:

• Flood Insurance Rate Map Zone
• Base Flood Elevation
• Foundation Type
• Structural Elevation (Special Flood Hazard Area Only)

RR 2.0 will consider these variables instead:

• Distance to Flooding Source & Flood Type
• Building Occupancy  
• Construction Type
• Foundation Type
• Ground Elevation
• First Floor Height
• Number of Floors
• Prior Claims

Your WYO may ask you, the agent, to provide these details about each of the properties you write NFIP coverage for, even for properties you have covered for years, because the system may not be able to generate a RR 2.0 rate for that property if it lacks the data to do so.

RR 2.0 will not require the use of Elevation Certificates (ECs). However, ECs have not been eliminated; a property’s EC may be used to lower a policyholder’s rate in the RR 2.0 system.

Agent Training Opportunities

FEMA

FEMA has been providing agent-specific training sessions for the past couple of months. While the sessions are often redundant, they are also full of information, and attending more than one may be helpful.

The sessions will be useful to agency principals, of course, but they are also likely to be valuable to other agents and to customer service representatives (CSRs). We encourage agency principals to make these sessions available to anyone in their agencies who services NFIP flood insurance policies.

Below are registration links for its September training sessions. Please note that each session has a limited capacity. If your preferred session is full, please let us know so that we can ask FEMA to provide additional opportunities beyond those listed here.

September 7	10 a.m. – noon Central Time	REGISTER
September 7	2 p.m. – 4 p.m. Central Time	REGISTER
September 8	2 p.m. – 4 p.m. Central Time	REGISTER
September 9	2 p.m. – 4 p.m. Central Time	REGISTER
September 14	2 p.m. – 4 p.m. Central Time	REGISTER
September 16	10 a.m. – noon Central Time	REGISTER
September 21	10 a.m. – noon Central Time	REGISTER
September 23	2 p.m. – 4 p.m. Central Time	REGISTER

To register, please use the links above. These webinars are free to attend, but spaces are limited, so please register early.

Insurance agent continuing education course approval and credits vary by state. Please CLICK HERE for information about your state.

WYOs

The NFIP works with 55 WYOs, and each WYO’s Risk Rating 2.0 interface will have a slightly different look and feel. And, as mentioned above, your WYO may ask you for new details about the properties you service to ensure the rating engine has the data it needs to produce a property-specific rate. For these reasons, agents with NFIP policies should reach out to their WYOs as soon as possible.

If you have any questions, please reach out to Lauren Pachman, PIA National’s Counsel and Director of Regulatory Affairs, at Lpachman@pianational.org.