On April 15, 2014 the NFIP released a bulletin confirming that Phase I Implementation of Homeowners Flood Insurance Affordability Act ("HFIAA") will begin on May 1, 2014. While the details of implementation are still under discussion, we want to let our readers understand the two biggest changes:

• The NFIP has repealed the mandate to actuarially rate pre-FIRM buildings. Effective May 1, 2014 all qualifying, pre-FIRM buildings will be able to utilize the subsidized rates once again, regardless of the occupancy (e.g. single family, multi-family or "other residential", non-residential).
   
• The NFIP and WYO carriers are still determining how buildings forced into actuary rates will be identified so that the insured and insured's broker can be notified. Once buildings are identified and it is confirmed the subsidized, pre-FIRM rates are indeed more favorable, the policies will be re-rated for a refund to the insured of the difference in premium.