Issued: June 25, 2008

All ideas should be considered, even if in their complete presented form may raise concerns.  The best solutions will come from bits and pieces of many ideas. 

In its current form PIA is concerned that such a program, as Nationwide is proposing, could be viewed as an attempt to get Congress to pay for wind damage connected to hurricanes (even if some/a portion of flooding accompanies the event) that may currently be a legal obligation under the current wind damage terms of property policies.  This is exactly what PIA does not want to happen, and one reason why we’ve opposed wind being added to the NFIP program.

In addition, we believe that the Federal Emergency Management Agency (FEMA) already has administrative law authority to approve such a special product request.  Nationwide can develop such an insurance policy, and then submit it to FEMA and the state Departments of Insurance for approval. 

In this regard, Nationwide’s proposal could be seen as an end run around FEMA, the Department of Homeland Security (DHS) and state insurance regulation with their request to have “this one product” under the oversight of the Treasury Department.  There is no authority for Treasury to regulate the business of insurance, or the NFIP program, or FEMA.