The Role of Actuarial Soundness in the National Flood Insurance Program
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The Role of Actuarial Soundness in the National Flood Insurance Program Kevin Bingham, Mark Charron, Gerald Kirschner, Richard Messick, and Shama Sabade Deloitte Consulting LLP October 2006 Prepared under subcontract to the American Institutes for Research as part of the 2001–2006 Evaluation of the National Flood Insurance Program This page left blank intentionally. The Role of Actuarial Soundness in the National Flood Insurance Program Prepared as part of the 2001-2006 Evaluation of the National Flood Insurance Program Kevin Bingham, Mark Charron, Gerald Kirschner, Richard Messick, and Shama Sabade Deloitte Consulting LLP City Place I, 33rd Floor 185 Asylum Street Hartford, CT 06103-3402 October 2006 REPORTS IN THE EVALUATION OF THE NATIONAL FLOOD INSURANCE PROGRAM This Evaluation consists of a series of reports assessing questions identified and prioritized by a steering committee about the National Flood Insurance Program. The reports of the Evaluation will be posted on the FEMA website as they are finalized. The website URL is http://www.fema.gov/business/nfip/nfipeval.shtm. The reports in the Evaluation are: The Evaluation of the National Flood Insurance Program – Final Report American Institutes for Research and NFIP Evaluation Working Group Assessing the Adequacy of the National Flood Managing Future Development Conditions in Insurance Program's 1 Percent Flood Standard. the National Flood Insurance Program. Galloway, Baecher, Plasencia, Coulton, Blais, Nguyen, Tate, Dogan, Petrow, ABSG Louthain, and Bagha, Water Policy Consulting; and Mifflin and Jones. Collaborative, University of Maryland. The National Flood Insurance Program’s Costs and Consequences of Flooding and Mandatory Purchase Requirement: Policies, the Impact of the National Flood Insurance Processes and Stakeholders. Tobin and Calfee, Program. Sarmiento and Miller, Pacific American Institutes for Research. Institute of Research and Evaluation. The National Flood Insurance Program’s Developmental and Environmental Impacts of Market Penetration Rate: Estimates and Policy the National Flood Insurance Program: A Implications. Dixon, Clancy, Seabury, and Review of Literature. Rosenbaum, American Overton, RAND Corporation. Institutes for Research. Performance Assessment and Evaluation The Developmental and Environmental Impact Measures for Periodic Use by the National of the National Flood Insurance Program: A Flood Insurance Program. Miller, Langston, Summary Research Report. Rosenbaum & and Nelkin, Pacific Institute of Research and Bouleware, American Institutes for Research. Evaluation. An Evaluation of Compliance with the National The Role of the Actuarial Soundness in the Flood Insurance Program Part A: Achieving National Flood Insurance Program. Bingham, Community Compliance. Monday, Grill, Charron, Kirschner, Messick and Sabade, Esformes, Eng, Kinney and Shapiro, American Deloitte Consulting. Institutes for Research. State Roles and Responsibilities in the National An Evaluation of Compliance with the National Flood Insurance Program. Mittler, Morgan, Flood Insurance Program Part B: Shapiro, and Grill, American Institutes for Are Minimum Building Requirements Being Research. Met? Mathis and Nicholson, Dewberry. Evaluation of the National Flood Insurance Program’s Building Standards. Jones, Coulbourne, Marshall, and Rogers, Christopher Jones and Associates. i The research described in this report was funded with Federal funds from the Federal Emergency Management Agency under contract # 282-98-0029 and under subcontract to the American Institutes for Research. The content of this publication does not necessarily reflect the views or policies of the Federal Emergency Management Agency, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government. Deloitte Consulting, LLP is one of the largest and most highly regarded professional service organizations in the world. Our firm has more than 100 offices and 30,000 people across the United States. Our international organization, Deloitte Touche Tohmatsu, is one of the world’s largest accounting and auditing, tax, consulting and related services firms with more than 120,000 people in over 140 countries. We attribute our success as a firm to our strong commitment to client service through innovative approaches to solving problems; quality services; personnel with outstanding capabilities and expertise; and personal and frequent contact with our clients. Established in 1946, with headquarters in Washington, D.C., the American Institutes for Research (AIR) is an independent, nonpartisan not-for-profit organization that conducts behavioral and social science research on important social issues and delivers technical assistance both domestically and internationally in the areas of health, education, and workforce productivity. ii Kevin Bingham, Principal including property/casualty insurance companies. Kevin Bingham, ACAS, MAAA is a Specifically, he has conducted business process Principal in Deloitte Consulting’s Actuarial & reviews of insurance claims and underwriting units, Insurance Solutions Group. He has over 15 years of including those associated with the NFIP’s Write insurance consulting experience for both public and Your Own (WYO) program. He received a BA private sector clients, including property/casualty degree from Dickinson College and is a Member, insurance companies and government. Mr. Society of Chartered Property Casualty Underwriters Bingham’s unique role at Deloitte Consulting, which (CPCU) and a Connecticut Licensed Insurance involves working for the insurance consumer, Advisor. insurance department and the insurance/reinsurance industry, has given him a unique perspective on Shama S. Sabade, Senior Manager, ACAS, MAAA trends affecting all sides of the insurance purchasing Shama Sabade is a Senior Manager with decision. Mr. Bingham is currently the chairperson Deloitte Consulting LLP at McLean, VA. Her of the American Academy of Actuaries (AAA) responsibilities include reserving, pricing, merger and Medical Malpractice Committee and official acquisition due diligence, financial modeling, spokesperson on medical malpractice issues for the strategic planning, new product development and AAA in Washington. He is a graduate of Clarkson audit support. She also manages actuarial operations University in Potsdam NY with a BS in mathematics. in Hyderabad, India office of Deloitte’s Actuarial and Insurance Solutions Practice. She has over 14 years Mark P. Charron, Principal of experience as a Property & Casualty actuary. She Mark P. Charron is a Principal with Deloitte also provided technical expertise to Federal Consulting LLP. He is the National Service Line Emergency Management Agency (FEMA) on Leader for the firm’s Actuarial and Insurance National Flood Insurance Program including trend Solutions service area and a Senior Member of analysis, frequency and severity predictions, Deloitte’s National Insurance Practice. He has been effectiveness of present rate levels etc. as a Senior working with major organizations on key risk and Actuary working for Computer Sciences Corporation. insurance issues as a consultant for over 25 years. She received her B.E. degree in Electrical Mr. Charron founded Deloitte’s Insurance Risk Engineering, and her M.B.A. in Finance from the Management Practice and has been a key contributor University of Mumbai, India. She is an Associate of in Deloitte’s development of Enterprise Risk Casualty Actuarial Society and Member of American Management for Insurance, Deloitte’s Insurance Academy of Actuaries. Industry POV on Claims, and The Life Loan Product development. He was awarded the James G Hellmuth Gerald Kirschner, Senior Manager, FCAS, MAAA Unit Citation Award by the Port Authority of NY & Gerry Kirschner joined Deloitte Consulting LLP in NY for his efforts in leading Deloitte assistance with 2004. Prior to Deloitte Consulting, he developed and the World Trade Center Loss Recovery efforts sold the MoSes actuarial software for Classic following the terrorist’s attacks of 9-11-01. He holds Solutions, the software arm of Tillinghast. Before a Bachelor of Science degree in Insurance that, he worked several years each at Liberty Mutual Management from the University of Rhode Island Insurance Company, Ernst & Young and Aetna Life and received his designation as a Chartered Property & Casualty Company. Gerry’s areas of Casualty Underwriter in 1985. He is also a Board of specialization relate to the analysis of capital needs Trustee member for the LCMS Foundation based in and capital usage and stochastic approaches to St. Louis Missouri. reserve analysis. He is a long-standing member of the American Academy of Actuaries Risk-Based Richard Messick, Senior Manager Capital Committee and has served on several other Richard Messick, CPCU, AAI is a Senior American Academy and Casualty Actuarial Society Manager with Deloitte Consulting in Hartford, CT. Committees, including the Committee on Property- He has over 19 years of risk management consulting Liability Financial Reporting and Dynamic Financial experience for both public and private sector clients, Analysis Committee. iv TABLE OF CONTENTS EXECUTIVE SUMMARY I Introduction i Methodology iii Findings iii Recommendations ix 1. INTRODUCTION AND PROJECT SCOPE 1 1.1. Background on the Evaluation of the National Flood Insurance Program 1 1.2 Objective of the Study 1 2. RELIANCE AND LIMITATIONS 3 3. NFIP BACKGROUND 5 3.1 NFIP Overview 5 3.2 NFIP Historical Financial Results 7 4. ACTUARIAL