Privacy Impact Assessment
DHS/FEMA-048
NFIP Direct Serving Agent (NFIP Direct) System
Page 3
Repetitive Loss (SRL) policies.
NFIP Direct also collects and uses sensitive PII (SPII) to process
commission payments to insurance agents who facilitate the purchase of the aforementioned
policies. Additionally, SPII such as Social Security number (SSN) may be included on an
individual’s proof of primary residency
document provided to his or her insurance agent. FEMA
does not need or request the SSN.
The NFIP Direct System is a Government cloud-based IT system used to carry out the
duties of NFIP Direct with several multi-directional exchanges with external entities, which
streamline processes, minimize the amount of effort required from the users of the system, and
enhance the customer experience. For instance, FEMA’s exchange with the Department of
Treasury’s pay.gov website (www.pay.gov)
allows policyholders to pay electronically through
Treasury’s pay.gov website, which in turn, sends NFIP Direct System notification of successful
payment. Through a similar exchange, FEMA also meets its legal requirements to report income
for tax-related purposes to the Internal Revenue Service (IRS). This exchange includes the sharing
of tax identification numbers (TIN), which may be the SSN of insurance companies or agents that
issue flood insurance policies.
Issuing a New SFIP
Typically, a SFIP begins with an individual or organization, such as a home owner, renter,
mortgage lender, or owner of a commercial property, who is interested in or required to have flood
insurance. Should the interested party choose an insurance agent that issues through NFIP Direct,
the individual or organization requests flood insurance by completing the FEMA Form (FF) 086-
0-1, Flood Insurance Application
(Office of Management and Budget (OMB) No. 1660-0006).
Through the application, the agent acquires detailed information about the prospective
policyholder and the property such as name, address, and supporting documents. Supporting
documentation such as Driver’s License, Homestead Tax Credit Form for Primary Residence,
and
documents showing where children attend school are used to validate address and property
information on FF 086-0-1. The agent submits the completed FF 086-0-1 and supporting
documentation to NFIP Direct by mail, fax, or by electronic submission through a secure web
portal into the NFIP Direct System (www.NFIPDirect.fema.gov). If the agent submits the
application via hard copy, a NFIP Direct employee scans all paper documents received, including
declared disaster and do not have SFIPs.
SRL are policies issued directly by NFIP Direct that provide coverage to property owners for properties that have a
repetitive flood loss and NFIP claims history. These SRL policies generally involve higher premiums and require
additional burden to maintain and process.
The Homestead Tax Credit Form differs by state, but most contain SSN. The form is one of several accepted forms
of proof of primary residence. It is at the policyholder’s discretion which acceptable form of proof they provide to
FEMA. FEMA does not use the SSN on the form, and NFIP Direct redacts the SSN during the processing of the
document.
The PIA for Pay.gov is accessible at https://www.fiscal.treasury.gov/fsreports/rpt/fspia/paygov_pia.pdf.
https://www.fema.gov/media-library/assets/documents/154.