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E&O Risk Management Alert: National Flood Insurance Program (NFIP)

An alert regarding the National Flood Insurance Program (NFIP) program lapse was sent Friday, Oct. 24, to Swiss Re errors & omissions policyholders. The email outlines guidance for agents on how to support clients and manage operations during this period.

E&O Risk Management Alert:
National Flood Insurance Program (NFIP)

Overview

As of September 30, 2025, the National Flood Insurance Program (NFIP) has lapsed due to a lack of Congressional reauthorization. This impacts on your carrier’s ability to issue, renew, or modify NFIP policies. The following guidance outlines how you should support clients and manage operations during this period.

Key Impacts

  • No new NFIP policies can be issued.
  • Renewals are suspended unless payment was received prior to the lapse.
  • Policy changes (e.g., coverage increases, endorsements) are not permitted.
  • Claims on active policies will still be processed.
  • Floodplain management regulations remain in effect.

Action Steps for Agents

  1. Client Communication
  • Proactively reach out to all clients to explain the situation. Use our email template as a starting point. 
  • Reassure them that existing coverage remains valid and claims can be filed.
  • Offer to assist with private flood insurance alternatives.
  1. Private Market Solutions
  • Familiarize yourself with available private flood insurance carriers.
  • Evaluate coverage options, underwriting criteria, and pricing.
  • Ensure clients understand differences in coverage and lender acceptance.
  1. Policy Management
  • Premium Payments – some carriers may have changed their direct bill notification practices due to the lack of reauthorization prior to October 1, 2025. We recommend agencies should not deviate from your standard practice within your agency.
  • Do not quote or bind new NFIP policies until reauthorization is confirmed.
  • Track pending renewals and policy changes for follow-up once the program resumes.
  1. Stay Informed
  • Monitor FEMA, industry bulletins, and Congressional updates.
  • Share relevant news with agency personnel and clients as appropriate.
  • Be prepared to resume NFIP operations quickly once reauthorization occurs.

Sample Client Communication