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Flood Risk and Insurance CIPR STUDY Flood Risk and Insurance Contributions By David Altmaier Howard Kunreuther Andy Case Nicholas Lamparelli Mike Chaney Sonja Larkin-Thorne Ned Dolese Ivan Maddox James J. Donelon Teresa D. Miller Raymond G. Farmer Paresh Patel Dave Jones Brooke Stringer Dimitris Karapiperis Swenja Surminski Carolyn Kousky Thomas Travis APRIL 2017 Flood Risk and Insurance Prologue By Eric C. Nordman, CPCU, CIE Director, CIPR This Center for Insurance Policy and Research (CIPR) study presents independent research the purpose of which is to inform and disseminate ideas to regulators, consumers, academics and financial services professionals. CIPR studies are available at no cost on the CIPR website: http://www.naic.org/cipr_special_reports.htm. This study would not have been possible without the valuable contributions by members of the CIPR, state insurance regulators and the other invited authors noted for their expertise in flood insurance. All the contributors are listed on page ii. Disclaimer: This study represents the opinions of the author(s) and is the product of professional research. It is not intended to represent the position or opinions of the National Association of Insurance Commissioners (NAIC) or its members, nor is it the official position of any NAIC staff members. Any errors are the responsibility of the author(s). Acknowledgements: The authors are grateful to those who reviewed and contributed to the study and helped improve it with their insightful comments. Special thanks to the following for their valued comments and edits: Brooke Stringer, Financial Policy & Legislative Advisor, NAIC Government Relations Office; Eric C. Nordman, CIPR Director; and Shanique Hall, CIPR Manager. CIPR Study Series 2017-1 Date: April 2017 i Authors: David Altmaier, Commissioner, Florida Office of Insurance Regulation: [email protected] Andy Case, Director of Consumer Services, Mississippi Insurance Department: [email protected] Mike Chaney, Commissioner, Mississippi Insurance Department: [email protected] Ned Dolese, President, Coastal American Insurance Company: [email protected] James J. Donelon, Commissioner, Louisiana Department of Insurance: [email protected] Raymond G. Farmer, Director, South Carolina Department of Insurance: [email protected] Dave Jones, Commissioner, California Department of Insurance: [email protected] Dimitris Karapiperis, Research Analyst, NAIC Center for Insurance and Policy Research: [email protected] Carolyn Kousky, Fellow, Resources for the Future: [email protected] Howard Kunreuther, Professor, Wharton School, University of Pennsylvania: [email protected] Nicholas Lamparelli, VP of Cat Modeling and Analytics Partner, QBE: [email protected] Sonja Larkin-Thorne, NAIC Consumer Representative: [email protected] Ivan Maddox, Product Manager, Intermap Technologies: [email protected] Teresa D. Miller, Commissioner, Pennsylvania Insurance Department: [email protected] Paresh Patel, Chairman & CEO, HCI Group: [email protected] Brooke Stringer, Financial Policy & Legislative Advisor, NAIC Government Relations Office: [email protected] Swenja Surminski, Senior Research Fellow, London School of Economics: [email protected] Thomas Travis, NAIC Liaison, Louisiana Department of Insurance: [email protected] ii Contents Foreword………………………………………………………………………………………………………………………………………….……...1 People and Property at Risk………………………………………………………………………………………………………………………6 …………. Introduction………………………………………………………………………………………………………………………………….6 …………. Floods Have Become Hot Topic……………………………………………………………………………………………….…...6 Historical Flood Events and Losses…….………………………………………………………….………………….…….…....7 Current Value and Distribution of Property in Harm’s Way……………………………………………….…………10 Potential Flood losses per Major Catastrophe Modelers..…………………………………..……………………….10 Factors Affecting Future Flood……………………………………………………….……………………………………………12 Flood Purchase Decision……………………………………………………………………………………………………………………..….17 ……………Role of Intuitive and Deliberative Thinking.…….………………………………………………………………………..18 ……………Purchase of Flood Insurance……………………….……………..…….……………………………………………………...19 The National Flood Insurance Program: Yesterday, Today and Tomorrow……………………………………………..22 …………….Introduction………………………………………………………………………………………………………………………..…..23 …………….History of the NFIP…………………………………….…………………………………………………………………………….24 …………….Structure of the NFIP………………………………..………………………………………………………………………….….26 ……………Addressing Affordability in the NFIP…………………………………………………….………………………………....38 Modifying the NFIP.…..…..….………………………….…………………………………………………………………..….…42 Section Conclusion..………..…………………..………………………………………………………………………………..…44 Private Sector Flood Insurance………………………………………………………………………………………………………………46 Current Options..........................................................................................................................47 ……………Pros & Cons of Options……………………………………………………………………………………………………………48 ……………Towards an All-Hazards Homeowners Insurance Policy………………………………………………….…….…49 iii Policy Alternatives and Potential Future Flood Insurance Regimes…………………………………………………….……51 ……………..Flood Insurance Costs…………………….…………………….……………………………………………………..………….52 ………….….Insurance Industry Appetite to Write Flood Insurance….…………………………………………………….…..52 ……………..Private Sector Capacity to Cover Potential Flood Losses…….…………………………………………………….54 Ability to Accurately Assess Flood Risk…….……………………………………………………………………………….55 Coastal Flooding……….…………………………………………………………………..……………………………………..….56 Inland Flooding……………….……………………………………………………………………………………….……………...57 Ability to Develop Actuarially Sound Prices…….……………………………………………………………………..…58 Underwriting Flood Insurance………………………………………………………………………….………………………59 Challenges for Insurers Entering the Flood Insurance Market………………………………………………....60 Can Private Sector and Government Flood Insurance Coexist?……….…..………………….……………….62 Lessons from Other Government-Supported Programs….……………………….…….………………………..63 Tension Between Private Insurance and Government Disaster Relief…………….………………..……...66 Section Conclusion……………………….………………………………………………………………………………………….66 Flood Insurance Regimes around the World.............................................................................................67 Flood Re from the U.K.……………………….……………………………..……………………………………………..…..….68 Flood Insurance Regimes in Other Developed Economies.………………………………………………………..73 The Consumer Challenge: The Need for More Education, Protection and Choice…………………………..……..76 Introduction………………………………………………………………………………………………………….…………………..77 Consumer Education and the Need for Coverage……..…….…………………………………………………………77 NFIP Consumer Experience………………………………………………………………………………………………………..78 Consumer-Centric Options and Solutions…………………………………………………………………………….......80 Section Conclusion………………………………………………………………………………………………………..…….......81 Industry Executive Views……………………………..…………………………………………………………………………….…………..82 Introduction………………………………………………………………………………………………………….…………………..83 Observations and Opportunities for Flood Insurance Enhancements ……………………….………………84 iv Admitted Private Market Flood: Lessons from Competing with the NFIP ……………….………………….89 State Insurance Regulator Views on Flood Risk and Insurance ..................................................................92 Introduction………….…………………………………………………………………………………………….………..……….…..93 California…………………………………………………………………………..…………………………………………………..…..94 Florida……………….……………………………………………………………..………………………………………………………..96 Louisiana.……………………..………………………………………………….………………………………………………..…….100 Mississippi………………………………………………………………………………………………………………………………..102 Pennsylvania……………………………………………………………………..……………………………………………………..105 South Carolina.……………………….………….………………………..…….…………………………………………………….109 State Insurance Regulatory Efforts and Initiatives………………………………….……..…………………………….………..112 Introduction…………….………………………………………………………………………………………….……………………113 Private Flood Insurance Market………………………………..……..…….………………………………………….….…113 Federal Legislative Efforts……………..…………………..……..…….…………………………………………..…….…...114 Surplus Lines Regulation.………………….………………………………………………………………………………..…...114 NAIC Guiding Principles for NFIP Reauthorization…….………………………………………………………..….…115 Section Conclusion…………….……………………………………………………………………….……………..…….........117 Study Conclusion………………………………….……..………………………………………………………………………………………..118 v Foreword Foreword 1 Foreword Foreword By Dimitris Karapiperis, Analyst, NAIC Center for Insurance Policy and Research The most common and most damaging natural disasters in the country are floods, with eight out of 10 costliest catastrophes in the U.S. involving flooding.1 No state, region or community across the country is really immune to floods. Aside from specific coastal areas vulnerable to hurricanes and therefore flooding, flash floods and inland flooding can happen anywhere, anytime. According to the Federal Emergency Management Agency (FEMA),2 in the past five years, all 50 states have experienced a flood or flash flood. Climatic changes and, in particular, the intensification of the global water cycle3 may significantly increase flood risk,4 as well as losses from flooding in the coming years. Responding to this risk is a societal and generational challenge requiring creative solutions from the federal and state governments, scientific community, and the insurance industry to develop effective mitigation and protection strategies along with recovery efforts. Damage caused by flood is not typically covered under a standard homeowners
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