[Federal Register Volume 61, Number 22 (Thursday, February 1, 1996)]
[Proposed Rules]
[Pages 3635-3644]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 96-2089]
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FEDERAL EMERGENCY MANAGEMENT AGENCY
44 CFR Part 62
RIN 3067-AC40
National Flood Insurance Program; Audit Program Revision
AGENCY: Federal Insurance Administration (FEMA).
ACTION: Proposed rule.
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SUMMARY: The Federal Insurance Administration (FIA) proposes to amend
its regulations regarding the manner in which its audits are conducted
under the National Flood Insurance Program's (NFIP) Write Your Own
(WYO) Program. The intent of the proposed regulations is to develop a
comprehensive, less burdensome, more efficient audit program. FIA
anticipates that these revisions will result in greater economy of
resources and new savings to the NFIP public.
DATES: We invite your comments and ask that you submit them no later
than March 18, 1996.
ADDRESSES: Please submit written comments to the Rules Docket Clerk,
Office of the General Counsel, Federal Emergency Management Agency, 500
C Street, SW., room 840, Washington, DC 20472, (fax) (202) 646-4536.
FOR FURTHER INFORMATION CONTACT: Roland E. Holland, Federal Insurance
Administration, Federal Emergency Management Agency, 500 C Street, SW.,
Washington, DC 20472, (202) 646-3439.
SUPPLEMENTARY INFORMATION: Recently, after reviewing the programs and
services provided to the NFIP public, the Federal Insurance
Administrator concluded that the services currently being provided
could be enhanced and improved by revising the audit procedures. As a
result, FIA intends to discontinue the self-audit program, along with
the triennial claims and underwriting operations reviews. The
``triennial'' audit will be revised to be conducted on a biennial
basis, and expanded to encompass greater claims and underwriting audits
that are to be conducted by Certified Public Accountant (CPA) firms,
selected by the WYO companies, at the companies' expense. These changes
are being made to facilitate improved management control over the audit
process. FIA believes these efforts will result in appreciable program
savings to both the WYO companies and the FIA.
National Environmental Policy Act
This proposed rule is categorically excluded from the requirements
of 44
[[Page 3636]]
CFR Part 10, Environmental Consideration. No environmental impact
assessment has been prepared.
Executive Order 12898, Environmental Justice
The socioeconomic conditions relating to this proposed rule were
reviewed and a finding was made that no disproportionately high and
adverse effect on minority or low income populations result from this
proposed rule.
Executive Order 12866, Regulatory Planning and Review
This proposed rule is not a significant regulatory action within
the meaning of section 2(f) of E.O. 12866 of September 30, 1983, 58 FR
51735, and has not been reviewed by the Office of Management and Budget
(OMB). Nonetheless, this proposed rule adheres to the regulatory
principles set forth in E.O. 12866.
Paperwork Reduction Act
In accordance with the provisions of the Paperwork Reduction Act of
1995, 44 U.S.C. 3501 et seq., the collections of information contained
in this proposed rule have been submitted to and approved by the Office
of Management and Budget. To request additional information or copies
of the OMB submissions, contact the FEMA Informations Collections
Officer, Muriel B. Anderson, by calling (202) 646-2625 or by writing to
FEMA, 500 C Street, SW., Washington, DC 20472. The approved collections
of information are:
OMB Number 3067-0169, Write Your Own (WYO) Program--To maintain
adequate financial control over Federal funds, the National Flood
Insurance Program requires each WYO company to meet the requirements of
the WYO Transaction Record Reporting and Processing Plan and to submit
monthly financial and statistical reports as required in FEMA
regulation 44 CFR Part 62, Appendix B. The number of respondents is
estimated at 105. The burden estimates per respondent are as follows:
Reconciliation Report, 30 minutes; Biennial Audit Administrative Review
Checklist, 1 hour; Monthly Financial and Statistical Reconciliation
Reports Certification Statement, 3 minutes; and Monthly Statistical
Transaction Reports Certification Statement, 3 minutes.
OMB Number 3067-0229, Mortgage Portfolio Protection Program
(MPPP)--Lending institutions, mortgage servicing companies and others
servicing mortgage loan portfolios can bring their mortgage loan
portfolios into compliance with the flood insurance purchase
requirements of the Flood Disaster Protection Act of 1973. The number
of respondents is estimated at 6,526. The burden estimates per
respondent are as follows: 150 hours for WYO companies to set up
initial operations under the MPPP; 30 minutes per lender to sign an
agreement with a WYO company to notify each mortgagor (3 notices at 10
minutes per notice); and 30 minutes for each mortgagor to ask questions
and respond to the notices.
Although the collections of information have been approved by OMB,
FEMA continues to solicit comments on (1) whether the collections of
information are necessary for the proper performance of the functions
of the agency, including whether the information will have practical
utility; (2) the accuracy of the agency's estimates of the burden of
the collections of information; (3) ways to enhance the quality,
utility, and clarity of the information to be collected; and (4) ways
to minimize the burden of the collections of information on those who
are to respond, including through the use of appropriate automated,
electronic, mechanical, or other technological collection techniques or
other forms of information technology.
Submit comments within 60 days of this notice to the Federal
Emergency Management Agency, Attention: Information Collections
Management, 500 C Street S.W., room 311, Washington, D.C. 20472.
Executive Order 12612
This proposed rule involves no policies that have federalism
implications under Executive Order 12612, Federalism dated October 26,
1987.
Executive Order 12778, Civil Justice Reform
This proposed rule meets the applicable standards of 2(b)(2) of
Executive Order 12778.
List of Subjects in 44 CFR Part 62
Flood insurance.
Accordingly, 44 CFR part 62 is proposed to be amended as follows:
PART 62--SALE OF INSURANCE AND ADJUSTMENT OF CLAIMS
1. The authority citation for Part 62 continues to read as follows:
Authority: 42 U.S.C. 4001 et seq.; Reorganization Plan No. 3 of
1978, 43 FR 41943, 3 CFR, 1978 Comp., p. 329; E.O. 12127 of Mar. 31,
1979, 44 FR 19367, 3 CFR, 1979 Comp., 376.
Sec. 62.23 [Revised]
2. Section 62.23 is revised to read as follows:
Sec. 62.23 WYO Companies authorized.
(a) Pursuant to section 1345 of the Act, the Administrator may
enter into arrangements with individual private sector property
insurance companies whereby such companies may offer flood insurance
coverage under the Program to eligible applicants for such insurance,
including policyholders insured by them under their own property
insurance business lines of insurance pursuant to their customary
business practices including their usual arrangements with agents and
producers, in any State in which such WYO Companies are licensed to
engage in the business of property insurance. Arrangements entered into
by WYO Companies under this subpart shall be in the form and substance
of the standard arrangement, entitled ``Financial Assistance/Subsidy
Arrangement'', a copy of which is included in Appendix A of this part
and made a part of these regulations.
(b) Any duly licensed insurer so engaged in the Program shall be a
WYO Company.
(c) A WYO Company is authorized to arrange for the issuance of
flood insurance in any amount within the maximum limits of coverage
specified in Sec. 61.6 of this subchapter, as Insurer, to any person
qualifying for such coverage under parts 61 and 64 of this subchapter
who submits an application to the WYO Company; coverage shall be issued
under the Standard Flood Insurance Policy.
(d) A WYO Company issuing flood insurance coverage shall arrange
for the adjustment, settlement, payment and defense of all claims
arising from policies of flood insurance it issues under the Program,
based upon the terms and conditions of the Standard Flood Insurance
Policy.
(e) In carrying out its functions under this subpart, a WYO Company
shall use its own customary standards, staff and independent contractor
resources, as it would in the ordinary and necessary conduct of its own
business affairs, subject to the Act and regulations prescribed by the
Administrator under the Act.
(f) To facilitate the marketing of flood insurance coverage under
the Program to policyholders of WYO Companies, the Administrator will
enter into arrangements with such companies whereby the Federal
Government will be a guarantor in which the primary relationship
between the WYO Company and the Federal Government will be one of a
fiduciary nature, i.e., to assure that any taxpayer funds are accounted
for and appropriately expended. In furtherance of this end,
[[Page 3637]]
the Administrator has established ``A Plan to Maintain Financial
Control for Business Written Under the Write Your Own Program'', a copy
of which is included in Appendix B of this part and made a part of
these regulations.
(g) WYO Companies shall not be agents of the Federal Government and
are solely responsible for their obligations to their insureds under
any flood insurance policies issued under arrangements entered into
with the Administrator.
(h) To facilitate the underwriting of flood insurance coverage by
WYO Companies, the following procedures will be used by WYO Companies:
(1) To expedite business growth, the WYO Company will encourage its
present property insurance policyholders to purchase flood insurance
and to transfer to the WYO Company, at the time of policy renewal,
business placed by its producers with the NFIP Bureau and Statistical
Agent.
(2) To confirm its underwriting practices to the underwriting rules
and rates in effect as to the NFIP, the WYO Company will establish
procedures to carry out the NFIP rating system and to provide its
policyholders with the same coverage as is afforded under the NFIP.
(3) The WYO Company may follow its customary billing practices to
meet the Federal rules on the presentment of premium and net premium
deposits to a Letter of Credit bank account authorized by the
Administrator and reduction of coverage when an underpayment is
discovered.
(4) The WYO Company is expected to meet the recording and reporting
requirements of the WYO Transaction Record Reporting and Processing
Plan. Transactions reported by the WYO Company under the WYO
Transaction Record Reporting and Processing Plan will be analyzed by
the NIP Servicing Agent. A monthly report will be submitted to the WYO
Company and the FIA. The analysis will cover the timeliness of WYO
Company submissions, the disposition of transactions that have not
passed systems edits and the reconciliation of the totals generated
from transaction reports with those submitted on the WYO Company's
reconciliation reports.
(5) If a WYO Company rejects an application from an agent or a
producer, the agent or producer should be notified so that the business
can be placed through the NFIP Servicing Agent, or another WYO Company.
(6) Flood insurance coverage will be issued by the WYO Company on a
separate policy form and will not be added, by endorsement, to the
Company's other property insurance forms.
(7) Premium payment plans can be offered by the WYO Company so long
as the net premium depository requirements specified under the NFIP/WYO
Program accounting procedures are met. A cancellation by the WYO
Company for non-payment of premium will not produce a pro rata return
of the net premium deposit to the WYO Company.
(8) NFIP business will not be assumed by the WYO Companies at any
time other than at renewal time, at which time the insurance producer
may submit the business to the WYO Company as new business. However, it
is permissible to cancel and rewrite flood policies to obtain
concurrent expiration dates with other policies covering the property.
Where the insurance agent or producer of record of a flood insurance
policy issued by the Administrator has authorized the NFIP, in writing,
to release policy information for the conversion of the NFIP coverage
to a designated WYO Company represented by the agent or producer of
record, in order to facilitate policy issuance and reduce
administrative burdens upon the NFIP and WYO Companies and their agents
and producers, countersignature requirements in the several States
shall not apply.
(i) To facilitate the adjustment of flood insurance claims by WYO
Companies, the following procedures will be used by WYO Companies.
(1) Under the terms of the Arrangement set forth at appendix A of
this part, WYO Companies will adjust claims in accordance with general
Company standards, guided by NFIP Claims manuals. The Arrangement also
provides that claim adjustments shall be binding upon the FIA. For
example, the entire responsibility for providing a proper adjustment
for both combined wind and water claims and flood-alone claims is the
responsibility of the WYO Company.
(2) The WYO Company may use its staff adjusters and/or independent
adjusters. It is important that the Company's Claims Department
verifies the correctness of the coverage interpretations and
reasonableness of the payments recommended by the adjusters.
(3) An established loss adjustment Fee Schedule is part of the
Arrangement and cannot be changed during an Arrangement year. This is
the expense allowance to cover costs of independent or WYO Company
adjusters.
(4) the normal catastrophe claims procedure currently operated by a
WYO Company should be implemented in the event of a claim catastrophe
situation. Flood claims will be handled along with other catastrophe
claims.
(5) It will be the WYO Company's responsibility to try to detect
fraud (as it does in the case of property insurance) and coordinate its
findings with FIA.
(6) Pursuant to the Arrangement, the responsibility of defending
claims will be upon the Write Your Own Company and defense costs will
be part of the unallocated or allocated claim expense allowance,
depending on whether a staff counsel or an outside attorney handles the
defense of the matter. Claims in litigation will be reported by WYO
Companies to FIA upon joinder of issue and FIA may inquire and be
advised of the disposition of such litigation.
(7) The claim reserving procedures of the individual WYO Company
can be used.
(8) Regarding the handling of subrogation, if a WYO Company prefers
to forego pursuit of subrogation recovery, it may do so by referring
the matter, with a complete copy of the claim file, to FIA. Subrogation
initiatives may be truncated at any time before suit is commenced
(after commencing an action, special arrangement must be made). FIA,
after consultation with FEMA's Office of the General Counsel (OGC),
will forward the cause of action to OGC or to the NFIP Bureau and
Statistical Agent for prosecution. Any funds received will be
deposited, less expenses, in the National Flood Insurance Fund.
(9) Special allocated loss adjustment expenses will include such
items as: nonstaff attorney fees, engineering fees and special
investigation fees over and above normal adjustment practices.
(10) The customary content of claim files will include coverage
verification, normal adjuster investigations, including statements
where necessary, police reports, building reports and investigations,
damage verification and other documentation relevant to the adjustment
of claims under the NFIP's and the WYO Company's traditional claim
adjustment practices and procedures. The WYO Company's claim examiners
and managers will supervise the adjustment of flood insurance claims by
staff and independent claims adjusters.
(11) The WYO Company will extend reasonable cooperation to FEMA's
Office of the General Counsel on matters pertaining to litigation and
subrogation, under paragraph (i)(8) of this section.
(j) To facilitate establishment of financial controls under the WYO
Program, the WYO Company will:
[[Page 3638]]
(1) Select a Certified Public Accountant (CPA) firm to conduct
biennial audits of the financial, claims and underwriting records of
the company. These audits shall be performed in accordance with the
Government Auditing Standards issued by the Comptroller General of the
United States (commonly known as yellow book). FIA further requires
that pre-selected policy and claims files the CPA firm is asked to
review are in addition to any files that the auditors may select for
their sample. A report of the detailed biennial audit conducted will be
filed with the FIA which, after a review of the audit report, will
convey its determination to the Standards Committee. The CPA firm
chosen to conduct the audit is expected to use qualified, skilled
persons with the requisite background in property insurance and a
knowledge of the NFIP. Persons performing claims audits are expected to
possess claims expertise which would allow them to ascertain whether
the scope of damage was proper, and if all applicable NFIP policy
provisions were properly followed. Persons performing underwriting
audits should be able to ascertain if the risk has been properly rated,
which would necessitate being aware of special NFIP rating situations,
such as elevated buildings.
(2) Meet the recording and reporting requirements of the WYO
Transaction Record Reporting and Processing Plan and the WYO Accounting
Procedures Manual. Transactions reported to the National Flood
Insurance Program's (NFIP's) Bureau and Statistical Agent by the WYO
Company under the WYO Transaction Record Reporting and Processing Plan
and the WYO Accounting Procedures Manual will be analyzed by the Bureau
and Statistical Agent and a monthly report will be submitted to the WYO
Company and the FIA. The analysis will cover the timeliness of the WYO
Company submissions, the disposition of transactions which do not pass
systems edits and the reconciliation of the totals generated from
transaction reports with those submitted on WYO Company reconciliation
reports.
(3) Cooperate with FEMA's Office of Financial Management on Letter
of Credit matters.
(4) Cooperate with FIA in the implementation of a claims
reinspection program.
(5) Cooperate with FIA in the verification of risk rating
information.
(6) Cooperate with FEMA's Office of the Inspector General on
matters pertaining to fraud.
(k) To facilitate the operation of the WYO Program and in order
that a WYO Company can use its own customary standards, staff and
independent contractor resources, as it would in the ordinary and
necessary conduct of its own business affairs, subject to the Act, the
Administrator, for good cause shown, may grant exceptions to and
waivers of the regulations contained in this title relative to the
administration of the NFIP.
(l)(1) WYO Companies may, on a voluntary basis, elect to
participate in the Mortgage Portfolio Protection Program (MPPP), under
which they can offer, as a last resort, flood insurance at special high
rates, sufficient to recover the full cost of this program in
recognition of the uncertainty as to the degree of risk a given
building presents due to the limited underwriting data required, to
properties in a lending institution's mortgage portfolio to achieve
compliance with the flood insurance purchase requirements of the Flood
Disaster Protection Act of 1973. Flood insurance policies under the
MPPP may only be issued for those properties that:
(i) Are determined to be located within special flood hazard areas
of communities that are participating in the NFIP, and
(ii) Are not covered by a flood insurance policy even after a
required series of notices has been given to the property owner
(mortgagor) by the lending institution of the requirement for obtaining
and maintaining such coverage, but the mortgagor has failed to respond.
(2) WYO Companies participating in the MPPP must provide a detailed
implementation package to any lending institution that, on a voluntary
basis, chooses to participate in the MPPP to ensure the lending
institution has full knowledge of the criteria in that program and must
obtain a signed receipt for that package from the lending institution.
Participating WYO Companies must also maintain evidence of compliance
with paragraph (l)(3) of this section for review during the audits and
reviews required by the WYO Financial Control Plan contained in
appendix B of this part.
(3) The mortgagor must be protected against the lending
institution's arbitrary placing of flood insurance for which the
mortgagor will be billed by being sent three notification letters as
described in paragraphs (l)(4) through (6) of this section.
(4) The initial notification letter must:
(i) State the requirements of the Flood Disaster Protection Act of
1973, as amended;
(ii) Announce the determination that the mortgagor's property is in
an identified special flood hazard area as delineated on the
appropriate FEMA map, necessitating flood insurance coverage for the
duration of the loan;
(iii) Describe the procedure to follow should the mortgagor wish to
challenge the determination;
(iv) Request evidence of a valid flood insurance policy or, if
there is none, encourage the mortgagor to promptly obtain a Standard
Flood Insurance Policy (SFIP) from a local insurance agent (or WYO
Company);
(v) Advise that the premium for an MPPP policy is significantly
higher than a conventional SFIP policy and advise as to the option for
obtaining less costly flood insurance; and
(vi) Advise that an MPPP policy will be purchased by the lender if
evidence of flood insurance coverage is not received by a date certain.
(5) The second notification letter must remind the mortgagor of the
previous notice and provide essentially the same information.
(6) The final notification letter must:
(i) Enclose a copy of the flood insurance policy purchased under
the MPPP on the mortgage's (insured's) behalf, together with the
Declarations Page.
(ii) Advise that the policy was purchased because of the failure to
respond to the previous notices, and
(iii) Remind the insured that similar coverage may be available at
significantly lower cost and advise that the policy can be cancelled at
any time during the policy year and a pro rata refund provided for the
unearned portion of the premium in the event the insured purchases
another policy that is acceptable to satisfy the requirements of the
1973 Act. ``(Approved by the Office of Management and Budget under OMB
control number 3067-0229.)''
Appendix B to Part 62 [Revised]
3. Appendix B to Part 62--National Flood Insurance Program, is
proposed to be revised to read as follows:
Appendix B to Part 62--National Flood Insurance Program
A Plan To Maintain Financial Control for Business Written Under the
Write Your Own Program
Under the Write Your Own (WYO) Program, the Federal Insurance
Administrator (Administrator) may enter into arrangements with
individual private sector insurance companies that are licensed to
engage in the business of property insurance, whereby these
companies may offer flood insurance coverage to eligible property
owners using their customary business practices. To facilitate the
marketing of flood
[[Page 3639]]
insurance coverage, the Federal Government will be a guarantor of flood
insurance coverage for WYO Company policies issued under the WYO
Arrangement. To ensure that any taxpayer funds are accounted for and
appropriately expended, the Federal Insurance Administrator (FIA)
and WYO Companies will implement this Financial Control Plan. Any
departures from the requirements of this Plan must be approved by
the Administrator. The authority for the WYO Program is contained in
Sec. 1345 of the National Flood Insurance Act of 1968, 42 U.S.C.
4081, and 44 CFR parts 61 and 62, Secs. 61.13 and 62.23. The WYO
Financial Assistance/Subsidy Arrangement (Arrangement) which is
included in appendix A of this part is hereby made a part of this
Financial Control Plan.
WYO Companies are subject to audit, examination, and regulatory
controls of the various states. Additionally, insurance company
operating departments are customarily subject to examinations and
audits performed by Company internal audit (and/or quality control)
departments and independent CPA firms. It is intended that this Plan
use to the extent possible, the findings of these examinations and
audits as they pertain to business written under the WYO Program
(Parts 3 and 4).
The WYO Financial Control Plan contains several checks and
balances that can, if properly implemented by the WYO Company,
significantly reduce the need for extensive on-site reviews of
Company files by the FIA staff or their designee. Furthermore, we
believe that this process is consistent with customary reinsurance
practices and avoids duplication of examinations performed under the
auspices of individual State Insurance Departments, NAIC Zone
examinations, and independent CPA firms.
The WYO Financial Control Plan requires the WYO Company to meet
the minimum requirements established by the Standards Committee. The
Standards Committee consists of four (4) members from FIA, one (1)
member from the Federal Emergency Management Agency's (FEMA's)
Office of Financial Management, one (1) member designated by the
Administrator who is not directly involved in the WYO Program, and
one (1) member from each of six (6) designated WYO Companies, pools
or other entities.
The WYO Financial Control Plan must require the WYO Company to:
1. Have a biennial audit of the flood insurance financial
statements and claims and underwriting activity conducted by an
independent accounting firm at the Company's expense to ensure that
the financial data reported to FIA accurately represents the flood
insurance activities of the Company. Require that the CPA firm's
audit be performed in accordance with GAO yellow book requirements.
Require that the auditors conduct their own review sample, even if
pre-selected policy and claims files are given to them for review.
2. Meet the recording and reporting requirements of the WYO
Transaction Record Reporting and Processing Plan. Transactions
reported to the National Flood Insurance Program's (NFIP's) Bureau
and Statistical Agent by the WYO Company under the WYO Transaction
Record Reporting and Processing Plan will be analyzed by the Bureau
and Statistical Agent and a monthly report will be submitted to the
WYO Company and the FIA. The analysis will cover the timeliness of
the WYO Company's submissions, the disposition of transactions that
do not pass systems edits, and the reconciliation of the total
generated from transaction reports with those submitted on the WYO
Company's reports (part 1).
3. Cooperate with FEMA's Office of Financial Management on
Letter of Credit matters.
4. Cooperate with FIA in the implementation of a claims
reinspection program (part 2).
5. Cooperate with FIA in the verification of risk rating
information.
6. Cooperate with FEMA's Office of the Inspector General on
matters pertaining to fraud.
The Standards Committee will review and make a recommendation to
the Administrator concerning any adverse action arising from the
implementation of the Financial Control Plan. Adverse actions
include, but are not limited to the FIA Operations Division's
recommendations not to renew a particular Company's WYO arrangement.
This Plan includes the following guidelines:
Part 1--Transaction Record Reporting and Processing Plan
Reconciliation Procedures
Part 2--Claims Reinspection Program
Part 3--Financial Audits, Underwriting Audits, Claims Audits, Audits
For Cause, and State Insurance Department Audits
Part 4--Reports Certifications
Part 5--WYO Financial Assistance/Subsidy Arrangement (Incorporated
by Reference)
Part 6--Transaction Record Reporting and Processing Plan
(Incorporated by Reference)
Part 7--Write Your Own (WYO) Accounting Procedures Manual
(Incorporated by Reference)
Part 1--Transaction Record Reporting and Processing Plan
Reconciliation Procedures
Transaction Record Reporting and Processing Plan Reconciliation
Objectives
The objectives are: To reconcile transaction detail with monthly
financial statements submitted by the WYO Companies; to assess the
quality and timeliness of submitted data; and to provide for the
identification and resolution of discrepancies in the data. The
reliance on computer processing to perform the review of transaction
and financial data will help minimize the necessity for on-site
audits of WYO Companies. Reconciliation of the statistical reports
submitted will be performed by the WYO Companies and independently
by the NFIP Bureau and Statistical Agent.
The Review of monthly financial statements and transaction level
detail will involve five areas:
A. Financial control;
B. Quality control (audit trails);
C. Quality review of submitted data;
D. Policy rating;
E. Timeliness of reporting; and
F. Monthly reports.
A. Financial Control
1. WYO Companies are required to submit a reconciliation report
(Exhibit ``A'') with the submission of transaction level detail.
This report will reconcile the transaction records data to the
financial report, explaining any discrepancies.
2. WYO Companies are required to submit, on a form approved by
the Administrator, a tape transmittal document with the submission
of the statistical tape containing transaction detail. This will be
used to validate record counts and dollar amounts.
3. The NFIP will review, at a minimum, the categories on the
attached format and produce a similar report reconciling the
transaction data to the monthly financial statement submitted by
each WYO Company.
4. To facilitate financial reconciliation, transaction records
which do not pass various edits employed by the NEIP to review the
quality of submitted data will be so identified, but still maintain
whenever possible until the error is corrected by the company in
order to reconcile all financial data submitted to the NFIP.
B. Quality Control
Transaction level detail will be maintained in policy and claim
history files for record-keeping and audit purposes.
C. Quality Review of Submitted Data
1. Transaction records will be edited for correct format and
values.
2. Relational edits will be performed on individual transactions
as well as between policy and claim transactions submitted against
those policies.
3. Record validation will be performed to check that the
transaction type is allowable for the type of policy or claim
indicated.
4. Errors will be categorized as critical or non-critical. The
rate of critical errors in the submission of statistical data will
be the basis by which company performance is reported to the
Standards Committee. Critical errors include those made in required
data elements. Required data elements:
a. Identify the policyholder, the policy, the loss, and the
property location;
b. Provide information necessary to rate the policy;
c. Provide information used in financial control; and
d. Provide information used for actuarial review of NFIP
experience.
5. Non-critical errors are those made in data elements reported
by the WYO Companies at their option.
D. Policy Rating
1. The rating will be validated by the NFIP for all policies for
which the following transactions have been submitted:
a. New Business;
b. Renewals;
c. Endorsements involving type A transaction records; and
d. Corrections of type A transaction records previously
submitted for premium transactions.
2. Incorrect rating will be considered a critical error.
E. Timeliness of Reporting
1. WYO Companies will be expected to submit monthly statistical
and financial
[[Page 3640]]
reports within thirty days of the end of the month of record.
2. The NFIP will provide reports based on review of submitted
data within thirty days after the due date or the first processing
cycle subsequent to the receipt of WYO Company submissions,
whichever is later.
F. Monthly Reports
1. Reports for each WYO Company's data submission will be sent
to the respective WYO Company and the FIA explaining any
discrepancies found by the NFIP review.
2. Reports to WYO Companies. Transaction records that fail to
pass the quality review or policy rating edits will be reported to
the appropriate Company in transaction detail with error codes,
classification of errors as either critical or non-critical and any
codes used by the Company to identify the source of the transaction
data.
3. Report to WYO Companies and the FIA:
a. Summary statistics will be generated for each monthly
submission of transaction data. These will include:
i. Absolute numbers of transactions read and transactions
rejected by transaction type; and
ii. Dollar amounts associated with transactions read and
transactions rejected.
b. Summary statistics for all policy and claim records submitted
to date (which may each be the result of multiple transactions) will
be generated, separately for critical and non-critical errors. These
will include:
i. Absolute number of policy and claim records on file and those
containing errors; and
ii. Relative values for the number of records containing
critical errors.
c. Control totals will be generated for tapes submitted to and
processed by the NFIP. This front-end balancing procedure will
include:
i. Numbers of records submitted according to the NFIP compared
with numbers of records submitted according to the WYO Company
transmittal document; and
ii. Dollar amounts submitted according to the NFIP compared with
dollar amounts submitted according to the WYO Company transmittal
document.
d. If there is any discrepancy between the NFIP reading of
dollar amounts from the tape and the WYO Company tape transmittal
document, then the monthly statistical tape submission will be
rejected and returned to the Company. The rejected tape must be
corrected and resubmitted by the next monthly submission due date.
e. In cases where the NFIP reconciliation of transaction level
detail with the financial statements does not agree with the
reconciliation report submitted by the WYO Company, a separate
report will be generated and transmitted to the Company for
resolution and to the FIA.
Reporting of Company Rating to the Standards Committee and the
Administrator
A. Satisfactory Rating
An annual end of the year report will be submitted to convey the
satisfactory rating of WYO Companies' submission of transaction data
and the reconciliation of this data with financial reports.
B. Unsatisfactory Rating
The report of an unsatisfactory rating will be submitted as soon
as errors and problems reach critical threshold levels. This rating
will be based on: Continuing problems in reconciling transaction
data with financial reports; statistics on the percentage of
transactions submitted with critical errors; the percentage of
policy and claim records on file that contain critical errors; and
late submission of statistical and financial reports.
Exhibit ``A''--WYO Statistical Tape Transmittal Document
Date Sent: ____________
WYOPrefix Code ____________--------------------------------------------
WYO Company Name:------------------------------------------------------
Address:---------------------------------------------------------------
----------------------------------------------------------------------
Reel Number (S) of Enclosed Tapes:-------------------------------------
----------------------------------------------------------------------
Density ____________ LRECL ____________
Blocksize ____________
File Name (DSN)--------------------------------------------------------
Contact Person---------------------------------------------------------
Contact Number---------------------------------------------------------
IBU Number ________________ (WYO Use Only
Monthly Reconciliation--Net Written Premiums
Company name-----------------------------------------------------------
Month/year ending------------------------------------------------------
Co. NAIC No------------------------------------------------------------
Date submitted---------------------------------------------------------
Preparer's name--------------------------------------------------------
Telephone No-----------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
Monthly statistical transactions report
Monthly financial report ------------------------------------------------------------------
Trans. code Record count Premium amount
----------------------------------------------------------------------------------------------------------------
Net Written premiums......................... $
(Income statement=Line 100).............. 11 .............. $
15 .............. ..............
17 .............. ..............
Unprocessed statistical:
(+) Prior month's........................ 20 .............. ..............
(-) Current month's...................... 23 .............. ..............
Other--Explain:
(+) Current month's...................... 26 .............. (-)
(-) Prior month's........................ 29 .............. (-)
14 and 81 .............. (+)
Total.................................. Total: Add 11 Through 23 less 26
and 29
Comments:
----------------------------------------------------------------------------------------------------------------
Monthly Reconciliation--Losses
Company name-----------------------------------------------------------
Month/year ending------------------------------------------------------
Co. NAIC No------------------------------------------------------------
Date submitted---------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
Loss/paid
Trans. code Record count recoveries
----------------------------------------------------------------------------------------------------------------
100 Net paid losses..........................
(Income statement line 115)
Unprocessed statistical:
31 .............. $
140 (+) Prior month's.................... 34 .............. ..............
37 .............. ..............
150 (-) Current month.................... 40 .............. ..............
[[Page 3641]]
43 .............. ..............
160 Salvage not to be reported by
transaction (explain)
170 Other--Explain....................... 46 and 61 .............. ..............
49 .............. ..............
64 .............. ..............
84 amd 87 .............. ..............
52 Recovery .............. ..............
Salvage .............. ..............
Subrogation .............. ..............
67 Recovery .............. ..............
Salvage .............. ..............
Subrogation .............. ..............
Total: (Sum of Lines 100, 140, 160, and Total: (Add 31, 34, 40 through 64 .............. ..............
170 less 150). less 52 and 67)
Comments:
----------------------------------------------------------------------------------------------------------------
Monthly Reconciliation--Special Allocated LAE
Company name-----------------------------------------------------------
Month/year ending------------------------------------------------------
Co. NAIC No------------------------------------------------------------
Date submitted---------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
Monthly statistical transaction report
Monthly financial report ------------------------------------------------------------------
Trans. code Record count Amounts
----------------------------------------------------------------------------------------------------------------
Special allocated loss adjustment expenses
(Other loss and LAE Calc.--Line 655)
71 .............. $
74 .............. ..............
Unprocessed statistical:
(+) Prior Month.......................... ................................. .............. ..............
(-) Current Month........................ ................................. .............. ..............
Other--Explain:
(1)...................................... ................................. .............. ..............
(2)...................................... ................................. .............. ..............
Total:................................. Total: .............. ..............
Comments:
----------------------------------------------------------------------------------------------------------------
Monthly Reconciliation--Net Policy Service Fees
Company name-----------------------------------------------------------
Month/year ending------------------------------------------------------
Co. NAIC No------------------------------------------------------------
Date submitted---------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
Monthly statistical transaction report
Monthly financial report -----------------------------------------------------------------
Record count Fee amount
----------------------------------------------------------------------------------------------------------------
Net Policy Service
Fees $____________ (Income Statement--Line
170)
Unprocessed statistical:
(+) Prior Month's ____________............
(-) Current Month's ____________..........
Other--Explain:
(1) ____________..........................
(2) ____________..........................
Total ____________ Total ____________..............
Comments:
----------------------------------------------------------------------------------------------------------------
(Approved by the Office of Management and Budget under OMB control
number 3067-0169.)
Part 2--Claims Reinspection Program
WYO--NFIP Claims Reinspection Program
To keep WYO-NFIP Claims Management informed, to assist in the
overall claims operation, and to provide necessary assurances and
documentation for dealing with GAO, Congressional Oversight
Committees, and the public, the FIA and WYO Companies have
established a Claims Reinspection Program.
The Program is comprised of the following major elements:
A. All files are subject to reinspection.
B. Files for reinspection may be randomly selected by flood
event, or size of loss, or class of business, as determined by WYO-
NFIP Claims Management.
C. WYO-NFIP Claims Management will utilize a binomial table to
define sample size for reinspections prior to payment. A larger
sample may be used depending upon error ratio.
D. An agreed upon sample of closed files, by event, will be
subjected to reinspection as well.
[[Page 3642]]
E. A WYO representative will conduct the reinspection,
accompanied by an NFIP General Adjuster.
F. A joint, single report will be issued by the WYO Company
representative and the NFIP General Adjuster.
G. Copies of reinspection reports will be forwarded to the
Claims Management of both the WYO Company and the NFIP.
Part 3--Financial Audits, Underwriting Audits, Claims Audits,
Audits for Cause, and State Insurance Department Audits
A. Biennial Financial Audits
1. Objectives of WYO Biennial Financial Audit. The biennial
financial audit is intended to provide the Federal Emergency
Management Agency with independent assessment of the quality of
financial controls over activities relating to the Company's
participation in the National Flood Insurance Program as well as the
integrity of the financial data reported to FEMA.
a. Participating WYO companies are responsible for selecting and
funding independent Certified Public Accounting firms to conduct the
biennial audits. Such costs are considered part of the normal
administrative cost of operating the WYO program and as such are
included in the WYO expense allowance.
b. The WYO Company's representative will be notified in writing
to arrange for a biennial audit. This notice should provide the WYO
Company at least 120 days to prepare for the biennial audit.
c. It is also intended that the biennial audit will reduce if
not eliminate the need for FEMA auditors or their designees to
conduct on-site visits to WYO companies in their review of financial
activity. However, the requirement may still exist for such visits
to occur as determined by the auditors. The CPA firm's audit shall
be performed in accordance with GAO yellow book requirements.
Further, the CPA firm is required to select its own sample, even
though FIA may provide them with pre-selected policy and claim files
for review. In addition, nothing in this section should be construed
as limiting the ability of the General Accounting Office or FEMA's
Office of Inspector General to review the activities of the WYO
Program.
d. The purpose of the biennial audit is to provide opinion on
the fairness of the financial statements, the adequacy of internal
controls, and the extent of compliance with laws and regulations.
B. Audits for Cause
In accordance with the terms of the Arrangement, the
Administrator, on his/her own initiative or upon recommendation of
the WYO Standards Committee or the FEMA Inspector General, may
conduct for-cause audits of participating companies. The following
criteria, in combination or independently may constitute the basis
for initiation of such an audit.
1. Underwriting
a. Excessively high frequency of errors in underwriting:
i. Issuing policies for ineligible risks.
ii. Issuing policies in ineligible communities.
iii. Consistent premium rating errors.
iv. Missing or insufficient documentation for submit for rate
policies.
v. Other patterns of consistent errors.
b. Abnormally high rate of policy cancellations or non-renewals.
c. Policies not processed in a timely fashion.
d. Duplication of policy coverage noted.
e. Problems with Rollover from National Flood Insurance Program
(NFIP) to WYO (duplication of coverage, timeliness of changeover).
f. Relational type edits indicate an unusually high or low
premium amount per policy for the geographical area.
g. Biennial audit results indicate unusual volume of errors in
underwriting.
2. Claims
a. Reinspection indicates consistent patterns of:
i. Losses being paid when not covered.
ii. Statistical information being reported on original loss
adjustment found to be incorrect on reinspection.
iii. Salvage/subrogation not being adequately addressed.
iv. Consistent overpayment of claims.
b. Unusually high count of erroneous assignments and/or claims
closed without payment (CWP). (WYO Company is paid a flat fee for
CWP cases where little or no work is done--risk is fraudulent CWP
cases).
c. Unusually low count of CWP. (May indicate inadequate follow-
up of claims submitted).
d. Average claim payments which significantly exceed the average
for the Program as a whole.
e. Lack of (adequate) documentation for paid claims.
f. Claims not processed in a timely fashion.
g. Consistent failure of WYO Company to receive authorization
for special allocated loss adjustment expenses prior to incurring
them.
h. High submission of Special Allocated Loss Adjustment Expenses
(SALAE).
i. Consistently high policyholder complaint level.
j. Low/high count of salvage/subrogation.
k. Biennial audit indicates significant problems.
3. Financial Reporting/Accounting
a. Consistently high reconciliation variations and/or errors in
statistical information.
b. Financial and/or statistical information not received in a
timely fashion.
c. Letter of Credit violations are found.
d. WYO Company is not depositing funds to the Restricted Account
in a timely manner, or funds are not being transferred through the
automated clearinghouse on a timely basis.
e. Premium suspense is consistently significant, older than 60
days, and/or cannot be detailed sufficiently.
f. Large/unusual balance in Cash-Other (Receivable and/or
Payable).
g. Large, unexplained differences in cash reconciliation.
h. Large/unusual balances or variations between months noted for
key reported financial data.
i. Financial statement to statistical data reconciliation sheets
improperly completed indicating proper review of information is not
being performed prior to signing certification statement.
j. Repeated failure to respond fully in a timely manner to
questions raised by FIA or its servicing agent concerning monthly
financial reporting.
k. Biennial audit indicates significant problems.
C. Underwriting Audit
1. Samples of new business policies, renewals, endorsements and
cancellations will be provided by the FIA with the biennial audit
instructions, including samples of the Mortgage Portfolio Protection
business, where applicable. The audit is to be conducted in
accordance with GAO yellow book requirements. The CPA firm may
supplement with its own sample of risks which were in-force during
all or part of the Arrangement Year under audit for detail testing.
2. Underwriting Audit Outline.
a. Review of the Underwriting Department's responsibilities,
authorities and composition.
b. Personal interviews with management and key clerical
personnel to determine current processing activities, planned
changes and problems.
c. Administrative review to verify compliance with company
procedures.
d. Thorough examination of a random sample of underwriting files
to measure the quality of work. The CPA firm is expected to provide
a representative sample of its review to substantiate its opinion
and findings. At a minimum, the files should be reviewed to verify
the following:
i. Policies are issued for eligible risks;
ii. Rates are correct and consistent with the amount of
insurance requested on the application.
iii. Waiting period for new business is consistent with
government regulations;
iv. Elevation certification or difference is correctly shown on
application;
v. The coverage does not include more than one building and/or
its contents per policy;
vi. No binder is effective unless issued with the authorization
of FIA;
vii. The FIRM zone shown on the application is applicable to the
community in which the property is located;
viii. Community shown on application is eligible to purchase
insurance under the NFIP;
ix. Information on type of building, etc., is fully complete;
x. Applicable deductibles are recorded;
xi. A new, fully completed application or a photocopy of the
most recent application, or similar documentation, with the
appropriate updates to reflect current information is on file for
each risk, including those formerly written by the NFIP Servicing
Facility;
xii. If any files to be audited are unavailable, determine the
reason for the absence.
e. Endorsement Processing.
1. Complete tasks as applicable.
2. Review requests for additional coverage to ensure that they
are subject to the waiting period rule.
[[Page 3643]]
3. Review controls established to ensure that no risk is insured
under endorsement provisions that are not acceptable as a new
business risk (i.e., a property located in a suspended community).
f. Cancellation Processing. Verify controls to ensure that one
of the necessary reasons for cancellation exists and that the
transaction is accompanied by proper documentation.
g. Renewal Processing. Determine controls to ensure that all
necessary information needed to complete the transaction is
provided.
h. Expired Policies. Determine controls to ensure that each step
is carried out at the proper time.
i. Observance of Waiting Period. Establish procedures to
document, as a matter of WYO Company business record and in each
transaction involving a new application, renewal, and endorsement,
that any applicable effective date and premium receipt rules have
been observed (44 CFR 61.11). Documentation reasonably suitable for
the purpose includes retention of postmarked envelopes (for three
(3) years) from date, date-stamping and retention (via hard copy or
microfilm process) of application, renewal and endorsement documents
and checks received in payment of premium; computer input of
document and premium receipt transactions and retention of such
records in the computer system; and other reasonable insurer methods
of verifying transactions involving requests for coverage and
receipts of premium.
D. Claims Audit Outline
1. Review of the Claims Department's responsibilities,
authorities, and composition.
2. Personal interviews with management and key clerical
personnel to determine current processing activities, planned
changes and problems.
3. Administrative review to verify compliance with company
procedures.
4. Thorough examination of a random sample of claims files which
may be provided by FIA to measure the quality of work. At a minimum,
the files should be reviewed to verify the following:
a. Verify controls to ensure that a file is set up for each
Notice of Loss received.
b. Review adjuster reports to determine whether they contain
adequate evidence to substantiate the payment or denial of claims,
including amount of losses claimed, any salvage proceeds,
depreciation and potential subrogation.
c. Ascertain that building and contents allocations are correct.
d. Determine whether the file contains evidence identifying
subrogation possibilities.
e. Verify that partial payments were properly considered in
processing the final draft or check.
f. Verify that the loss payees are listed correctly (consider
insured and mortgagee).
g. Verify that the total amount of the drafts or checks is
within the policy limits.
h. Ascertain the relevance and validity of the criteria used by
the carrier to judge effectiveness of its claims servicing
operation.
i. Confirm that when information is received from an independent
adjuster, the examiner either acts promptly to give proper feedback
with instructions or takes action to pay or deny the loss.
j. Determine whether the Claims Department is using an
``impression of risk'' program in reporting misrated policies, etc.
k. Where attempts at fraud occur, verify that these instances
are being reported to FIA for referral to the FEMA Inspector
General's office.
l. If any files to be audited are unavailable, determine the
reason for their absence. In undertaking this portion of the
biennial audit, the Administrative Review Checklist (Exhibit B)
below should be utilized.
Exhibit ``B''--Administrative Review Checklist
Policy #
Insured's name:
State:
Date of loss:
Date paid:
Date reported:
Amt. of loss: $
Bldg. $
Contents $
Adjusting firm:
Examiner's name:
Comments
1. Investigation and Adjustments
A. Application of Coverage Yes No N/A
(1) Insurable interest?........... [ ] [ ] [ ]
(2) Is loss from the flood peril?. [ ] [ ] [ ]
(3) Did loss occur within the
policy term?..................... [ ] [ ] [ ]
(4) Does location and description
of risk coincide with policy
information?..................... [ ] [ ] [ ]
(5) Were proper deductibles
applied?......................... [ ] [ ] [ ]
(6) Other insurance considered?... [ ] [ ] [ ]
(7) Other losses?................. [ ] [ ] [ ]
b. Application of Sound Adjusting
Practices
(1) Was adjuster's report accurate/
complete?........................ [ ] [ ] [ ]
(2) Was an attorney used in the
settlement?...................... [ ] [ ] [ ]
(3) Was a technical expert used in
the settlement?.................. [ ] [ ] [ ]
c. Documentation
(1) Are damages clearly
identified?...................... [ ] [ ] [ ]
(2) Are damages flood related?.... [ ] [ ] [ ]
(3) Are damages clearly and
completely itemized and
documented by the adjuster?...... [ ] [ ] [ ]
(4) Was depreciation considered?.. [ ] [ ] [ ]
(5) Has subrogation been
considered?...................... [ ] [ ] [ ]
(6) Has salvage been properly
handled?......................... [ ] [ ] [ ]
(7) Was salvage timely?........... [ ] [ ] [ ]
2. Supervision
a. Assignments
(1) Are assignments made promptly? [ ] [ ] [ ]
(2) Is insured contacted promptly? [ ] [ ] [ ]
b. Reserves
(1) Are initial reserves indicated
on the first report?............. [ ] [ ] [ ]
(2) Are they adequate?............ [ ] [ ] [ ]
(3) Does final settlement compare
favorably with last reserve
established?..................... [ ] [ ] [ ]
c. Diary Control
(1) Automatic?.................... [ ] [ ] [ ]
(2) Timely?....................... [ ] [ ] [ ]
(3) Is file reviewed at diary date
with examiner's comments?........ [ ] [ ] [ ]
d. Examiner Evaluation and Settlement
Performances
(1) Is examiner directing adjuster
when needed?..................... [ ] [ ] [ ]
(2) Are files documented?......... [ ] [ ] [ ]
(3) Is adequate control maintained
over in-house adjuster?.......... [ ] [ ] [ ]
(4) Is adequate control maintained
over outside adjuster?........... [ ] [ ] [ ]
[[Page 3644]]
e. Salvage and Subrogation Yes No N/A
(1) Is salvage evaluated by
salvors?......................... [ ] [ ] [ ]
(2) Is salvage disposed of
promptly?........................ [ ] [ ] [ ]
(3) Are salvage returns adequate?. [ ] [ ] [ ]
(4) Is potential subrogation being
promptly and properly
investigated?.................... [ ] [ ] [ ]
(5) Are proper subrogation forms
used?............................ [ ] [ ] [ ]
(6) Are subrogation and salvage
files properly opened, diaried,
and referred (if appropriate)?... [ ] [ ] [ ]
(7) Are recovery funds for
subrogation and salvage being
properly handled?................ [ ] [ ] [ ]
f. Suits
(1) Are suits properly identified? [ ] [ ] [ ]
(2) Are suits being properly
evaluated?....................... [ ] [ ] [ ]
(3) Are suits being referred to
attorneys promptly?.............. [ ] [ ] [ ]
(4) Are attorneys being advised as
to handling settlement or
compromise?...................... [ ] [ ] [ ]
(5) Are suits being properly
controlled?...................... [ ] [ ] [ ]
(6) Are suits files properly
diaried?......................... [ ] [ ] [ ]
(7)-(8) [Reserved]................ [ ] [ ] [ ]
g. Other
(1) Was there other coverage by
the WYO Company?................. [ ] [ ] [ ]
(2) Were damages correctly
apportioned?..................... [ ] [ ] [ ]
(3) Was a solo adjuster used?..... [ ] [ ] [ ]
(4) Were there prior flood claims? [ ] [ ] [ ]
(5) Were prior damages repaired?.. [ ] [ ] [ ]
(6) Were prior claim files
reviewed?........................ [ ] [ ] [ ]
(7) Was a congressional complaint
letter in file?.................. [ ] [ ] [ ]
(8) Was it responded to promptly?. [ ] [ ] [ ]
(9) Is the statistical reporting
correction file being properly
managed?......................... [ ] [ ] [ ]
E. State Insurance--Department Examination
1. It is expected that audits of WYO Companies by independent
accountants and/or state insurance departments, aside from those
conducted by the FIA or its designee, will include flood insurance
activity. When such audits occur, a financial officer for the WYO
Company will notify the FIA, identifying the auditing entity and
providing a brief statement of the overall conclusions that relate
to flood insurance and the insurer's financial condition, when
available. In the case of an audit in progress, a brief statement on
the scope of the audit should be provided to the FIA. A checklist
will be utilized for this reporting and will be provided to WYO
Companies by the FIA.
2. The WYO Companies will maintain on file the reports resulting
from audits, subject to on-site inspection by the FIA or its
designee. At the FIA's request, the WYO Company will submit a copy
of the auditor's opinion, should one be available, summarizing the
audit conclusion. ``(Approved by the Office of Management and Budget
under OMB control number 3067-0169)''
Part 4--Reports Certifications
A. Certification Statement for Monthly Financial and Statistical
Reconciliation Reports
I have reviewed the accompanying financial and statistical
reconciliation reports of XYZ Company as of ____________. All
information included in these statements is the representation of
the XYZ Company.
Based on my review (with the exception of the matter(s)
described in the following paragraphs, if applicable), I certify
that I am not aware of any material modifications that should be
made to the accompanying reports.
Signed-----------------------------------------------------------------
(Responsible Financial Officer)
Date-------------------------------------------------------------------
B. Certification Statement for Monthly Statistical Transaction Report
I have reviewed the accompanying statistical transaction report
control totals in conjunction with appropriate statistical
reconciliation reports. All information included in these reports is
the representation of the XYZ Company.
``(Approved by the Office of Management and Budget under OMB control
number 3067-0169.)''
Signed-----------------------------------------------------------------
(Responsible Reporting Officer)
Date-------------------------------------------------------------------
(Catalog of Federal Domestic Assistance No. 83.100, ``Flood
Insurance'')
Dated: January 25, 1996.
Elaine A. McReynolds,
Administrator, Federal Insurance Administration.
[FR Doc. 96-2089 Filed 1-31-96; 8:45 am]
BILLING CODE 6718-05-M
