To: Re: FEMA should provide homeowners with advance payments for loss prevention

FEMA should make minor revisions to the Homeowner Flood Form to provide policyholders with greater clarity: • In order to improve uptake of the endorsements and to reduce confusion, the Homeowner Flood Form should contain cross-references to the endorsements where the terms of the endorsements conflict with the terms of the general policy. [...] A homeowner may receive a discounted premium if, for example, the machinery in their home has been elevated to above the first floor, the home is elevated, the walls have proper flood openings to avoid damage to the foundation, or the home is watertight and certified floodproof.33 On the declarations page, FEMA should disclose to homeowners whether there are actions they can take to reduce flood r. [...] To the extent climate change results in the administration of substantially more flood insurance policies, necessitating training of additional insurance agents, only the component of additional training caused by the revisions to the form could be attributed to the Proposed Rule. [...] The Proposed Rule creates five new endorsements that will allow homeowners to tailor the coverage they receive.75 Based on FEMA’s presentation in the Proposed Rule, the Homeowner Flood Form will include language applicable to all policies, with the language of the various endorsements in appendices at the end. [...] 13 make things clearer for homeowners, and to remind homeowners of the availability of these endorsements, FEMA should reference the endorsement coverages within the body of the main policy document, where the policy and endorsements currently conflict.