As part of the Flood Insurance Reform Act (FIRA) of
2004, FEMA imposed a requirement that all agents who sell flood insurance must
complete a one-time flood course of at least three hours. The contents of the
course are spelled out in the federal legislation. (FAIA offers a four-hour
course meeting these requirements.) The Florida DFS issued an information bulletin
(DFS-01-2007) in January, 2007 stating that all agents who sell or may sell
flood insurance must complete the course. The DFS has stated that the
requirement also applies to an individual with a Customer Representative (4-40)
license. The memo goes on to say that the three hours are not additional hours,
only part of the basic requirement. Furthermore, the memo states only that
failure to obtain the course may jeopardize the ability to sell flood
insurance. In other words, no licensee will be found to be in non-compliance
with the Florida CE law, although they may lose the
ability to sell flood insurance if the class is not obtained. While FEMA has
not yet established a "drop dead" date for this requirement, at some point they
could instruct Write Your Own (WYO) flood carriers to "cut off" individuals
who have not completed an approved course. The best course of action is for all
licensees who sell or may sell and service flood insurance to complete the
course as soon as practical.
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