Cassidy, Hyde-Smith, Wicker Want GAO Study of New Flood Program to Include Key Indications
Addressed to GAO Comptroller General
"A third-party study of Risk Rating 2.0 may be useful if appropriately scoped, but it cannot be a substitute for
"We request that the following be included as one of the major questions to be examined in the GAO study: 'To what extent is Risk Rating 2.0 actuarially sound and transparent?' Our concern lies in that the study as designed might resolve the question of 'actuarial soundness' into an examination of whether Risk Rating 2.0 is 'doing what actuaries do,'" continued the senators.
The senators also express ongoing and growing concerns about the higher premiums levied on policyholders will result in an estimated 20 percent dropping their NFIP coverage. They also question the fiscal soundness of
"A complete study of Risk Rating 2.0 needs to address these discrepancies between affordability and fiscal balance. We would prefer to have enough transparency in this program to face this reality now in order to adopt flexibility with respect to actuarial niceties, and design a program that balances affordability with other objectives," concluded the senator.
The letter to Dodaro was accompanied by a related
* * *
Dear Comptroller Dodaro:
It is our understanding that you intend to release a Government Accountability Office (GAO) study this year on the
While we would welcome such an evaluation, we would like to note that our immediate concern with Risk Rating 2.0 is that the method and its supporting data have not been made transparent. The
We request that the following be included as one of the major questions to be examined in the GAO study: "To what extent is Risk Rating 2.0 actuarially sound and transparent?" Our concern lies in that the study as designed might resolve the question of "actuarial soundness" into an examination of whether Risk Rating 2.0 is "doing what actuaries do." That concern is further heightened by your intent to assess
We are also deeply concerned by
The era of unaffordable flood insurance ushered in by Risk Rating 2.0 led to a new
A complete study of Risk Rating 2.0 needs to address these discrepancies between affordability and fiscal balance. We would prefer to have enough transparency in this program to face this reality now in order to adopt flexibility with respect to actuarial niceties, and design a program that balances affordability with other objectives.
Beyond these conceptual concerns that we believe your study should examine, specific concerns that have been raised by many in the industry are listed below. We encourage your office to examine these requests and questions and answer them in your report.
* Report the error bands (confidence intervals) from the generalized linear model results for all the rating factors by region. Based on these error bands, evaluate the usefulness of the regressions for estimating flood insurance premiums with an accurate underlying estimate of expected annual damages.
* Evaluate the soundness of estimating rating factors on a regional, as opposed to a flood plain, basis together with discussion of the errors and biases that such an approach may introduce.
* Collect a significant sample of property-specific average annual damages using traditional hydrology/hydraulics models from
* Evaluate application of transparent and peer reviewed traditional methods (USACE, Hazard Mitigation) for computing property-specific average annual damages to compute actuarial premiums as compared with the opaque Risk Rating 2.0 methods.
* Evaluate the economic impact analysis in
* What are the immediate and long-term effects of eliminating grandfathered premiums on home values? What impact would this have on local property tax collections by municipalities?
* What is GAO's estimate of the expected attrition from the program from increasing cost on policyholders who do not have a mandated purchase requirement or others who simply cannot afford to pay the proposed rates?
* Does FEMA have the clear Congressional authority to make the draconian premium increases in Risk Rating 2.0?
* Should FEMA implement Risk Rating 2.0 through the Administrative Procedure Act?
* Should FEMA conduct an independent peer review of all models and methods in Risk Rating 2.0 as required by the
Thank you very much for your attention to this matter.
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Original text here: https://www.cassidy.senate.gov/newsroom/press-releases/cassidy-hyde-smith-wicker-want-gao-study-of-new-flood-program-to-include-key-indications


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