We are trying to determine what is meant by the statement “cancellation provisions that are as restrictive as the provision contained in the SFIP”. We are having trouble interpreting what is meant by “as restrictive as”.

In an example provided in a recent webinar and which we have encountered (see below) there are 2 exceptions noted in the Private Policy that are not in the SFIP.

Private Policy
Cancellation of Policy by You
1. You may cancel this policy in accordance with the applicable rule sand regulations of the NFIP.
a. Except with respect to cancellation reasons 1 and 2 in the NFIP Cancellation Guidelines, as policies are only eligible for one year's
return premium.
b. Except with respect to cancellation reason 4 in the NFIP Cancellation Guidelines, as policies may not be replaced with a duplicate NFIP
policy or another PFIP policy from a carrier different than The Flood Insurance Agency.

2. If you cancel this policy, you may be entitled to a full or partial refund of premium also under the applicable rules and regulations of the NFIP.

NFIP Policy:
E. Cancellation of the Policy By You
1. You may cancel this policy in accordance with the applicable rules and regulations of the NFIP.
2. If you cancel this policy, you may be entitled to a full or partial refund of premium also under the applicable rules and regulations of the NFIP.


The first exception limits returned premiums to 1 year. The NFIP Cancellation Guidelines provides for up to 2 years. Would limiting the returned premiums to less than two years be considered “as restrictive as” or would limiting the returned premiums to more than two years be considered “as restrictive as”?

The second exception states that for reason 4, duplicate policies may not be replaced with a policy from a different carrier, where the NFIP does not have such restrictions. Would this be considered “as restrictive as”?

It appears that the regulation allows insurers to be more restrictive in their policies with regard to cancellation provisions, but being less restrictive would be a problem. Is this a correct statement?

Any insight would be appreciate.
Thank you.

From the NFIP
Reason 1 - Building Sold or removed
Reason 2 - Contents Sold or Removed
Reason 4 - Duplicate NFIP Policies

Basically, they cannot terminate a policy for anything other than non-payment - just like a NFIP policy.

Premium refunds are not a cancellation policy.
I don't understand what you mean by reason 4.

Thanks Randy,
I didn't realize the example didn't copy over, so I updated my initial post, which contains the example. Reason 4 in the cancellation guidelines is for duplicate NFIP Policies.

Those are both borrower cancellations and not the insurance company.