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The National Flood Insurance Program’s Write Your Own (WYO) Program is a collaborative program between FEMA and the private insurance industry. It allows insurance companies to write and service flood insurance in their names. Through the WYO Program, “The [insurance] companies receive an expense allowance for policies written and claims processed while the federal government retains responsibility for underwriting losses.”

There have been a number of flood insurance adjusters over the years who have been accused of underpaying claims after a flood disaster. In 2015, Congress conducted an investigation into why there were so many underpayments after Superstorm Sandy in 2012, in which they acknowledged the habit of underpaying, also known as “running and gunning,” but they did not call out the practice as the exact cause of the lowballed insurance claims.

Instead, the report said it was “theoretically possible” for adjusters to make more by running and gunning, but they found “no evidence to support the hypothesis that engineers working in the NFIP reflexively downplay flood damage because that is what they are accustomed to doing in other insurance lines.”

Senate Democrats rejected this assessment, saying that the investigation “relied on questionable data, concluded too quickly and ignored evidence of widespread underpayments from the more than 2,000 lawsuits filed after Sandy in federal court.” The investigation was four months long and relied on FEMA’s data, which is known for having problems with record keeping.

An independent adjuster for a WYO is given incentives to adjust as many claims as they can without overpaying on any of them, for fear that an overpayment will be covered out of their own pockets. “rather than accurately estimating one or two losses in a day which may total $200,000, a FEMA percentage paid field adjuster will estimate 8 claims a day for a total of $1,000,000. So long as none of the individual estimates are overestimated, which results in a back payment to FEMA, the field adjuster has the financial incentive to estimate as much possible in total rather than as accurately as possible. If any of the estimates are found later by FEMA to result in an overpayment, the field adjuster may contractually pay out a lot more money from his own pocket than what he may have made in an entire catastrophe.”

This practice is along the same lines as “churn and burn,” which occurs after a major storm when independent adjusters are sent out to assess the property damages. They are paid based on the number of estimates they write, so they will try to hurry through each one, aiming to 10 every single day, to earn as much as possible in the wake of the disaster.

Keep in mind that ethical independent adjusters do exist, and will properly assess the damages and give the insurance company a reasonable estimate, they are just not talked about on the same level as the unethical adjusters who only care about how to make a quick buck off your disaster.


U.S. Senate Committee on Banking, Housing, and Urban Affairs. “Assessing and Improving Flood Insurance Management and Accountability in the Wake of Superstorm Sandy.” 22 Jun. 2015,

“Churn and Burn Insurance Adjusting.” United Claims Specialists, 10 Mar. 2020,

Merlin, Chip. “National Flood Claims Do Not Get Paid Properly Because the Only Incentive Is to Underpay: Property Insurance Coverage Law Blog: Merlin Law Group.” Property Insurance Coverage Law Blog, 7 Jan. 2017,

Ryan, Joe. “Schumer Rejects Insurance Program Findings.” Newsday, Newsday, 24 June 2015,

“The Write Your Own (WYO) Program.” The Write Your Own (WYO) Program |, 19 Dec. 2019,