The Federal Emergency Management Agency (FEMA) recently implemented a plan to require every National Flood Insurance Program (NFIP) policy—both new and renewing—to include both an agent and an agency National Producer Number (NPN). The new requirement is applicable to all NFIP policies with an effective date on or after January 1, 2024. The announcement was made in FEMA’s Bulletin W-23005. Most, if not all, systems immediately began requiring agents selling and renewing NFIP policies to provide both an agent and an agency NPN.

During an October meeting with FEMA, representatives assured PIA that, at least in 2024, NFIP policies would not be invalidated or non-renewed because an NPN was missing. That said, FEMA could always change its plans to begin comprehensive enforcement of this new requirement. If you have not already done so, we urge PIA members to reach out to their Write-Your-Own (WYO) partners to ensure that their systems are prepared to accommodate both agent and agency NPNs.

As this new requirement was being implemented, PIA became aware of five states—Iowa, Rhode Island, Tennessee, Vermont, and Wisconsin—that do not require insurance agencies to obtain business entity licenses. All five offer optional business entity licenses, but these states’ insurance departments do not require such licenses. Agencies in those states are less likely to have an agency NPN, particularly if they do not also engage in the business of insurance outside their states. Agencies that do not have NPNs are strongly encouraged to begin the process of requesting them from their insurance departments.

We are in touch with both the National Association of Insurance Commissioners (NAIC) and with FEMA to resolve this issue. As always, we will continue to pass information from FEMA to our members and solicit feedback from members about your experiences with FEMA and the NFIP.