Narrative of Changes Document for OMB Collection 1660-0086

Narrative of Changes Table

The purpose of the Narrative of Changes Table is to demonstrate changes to a collection since the previous approval.

Collection Title: National Flood Insurance Program – Mortgage Portfolio Protection Program (MPPP)
OMB Control No.: 1660-0086
Current Expiration Date: 12/31/2021
Collection Instruments (amended): two (2) existing instrument (no forms); one (1) new web form (being
added)
This is an amended submission (adding a new form) to a currently-approved collection; Notice of Action
dated 12/3/2018.
FEMA Form Number:
Title:
LOCATION
ICR Reference No:
201802-1660-002

N/A (newly added form)
Ask the Advocate Web Form

CURRENT TEXT
N/A (new form)

REVISED TEXT
This “Ask the Advocate” web form will allow the public to provide
information to the Office of the Flood Insurance Advocate (OFIA),
which includes all the data necessary for OFIA to perform its
Congressionally-mandated duties and responsibilities (see attached
screen shot). This online form will collect policyholder information and
requires a Privacy Act statement (see attached Privacy Act Statement).

.

.

“FEMA Form Number and Title” – Type the FEMA Form Number and Title of form.
“Location” – Identify page/block/etc. changes will be made
“Current Text” - Type Old text
.
“Revised Text” – Type New text.

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Ask the Flood Insurance Advocate a
Question
Indicates required fields
Do not enter Sensitive Personal Identifiable Information (PII) such as
SSN, DOB or driver's license number. Refer to the FEMA Privacy Policy
(/web/20190702233424/https://www.fema.gov/privacy-policy).
ATTENTION: It is the intent of the Office of the Flood Insurance
Advocate (OFIA) to respond to your inquiries within two (2) business
days. Replies from the OFIA will be addressed as: noreply
@salesforce.com On Behalf Of "Office of the Flood Insurance
Advocate". If you do not find a reply from the OFIA in your inbox within
two (2) business days, please check your spam or junk folders for a reply
and respond accordingly. Attachments cannot be transmitted initially
when using this web form. If necessary, attachments may be provided
with future communication.
First Name *

Last Name *

Email Address *

Confirm Email Address *

How did you hear of Advocate's Office? * - Select Please select source of advocate Knowledge



Ask the Flood Insurance Advocate a Question | FEMA.gov

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Contact Role *
Policyholder / Property Owner
Congressional Office
FEMA / FIMA Leadership
FEMA HQ Staff




Select a role. If applicable, select up to two (2) roles by holding down the Ctrl key on your keyboard.

State * - Select -



Zip Code *

Subject *

Question/Comment *
Add your phone number to your Question/Comment, if desired.

CAPTCHA
This question is for testing whether you are a human visitor and to prevent automated spam
submissions.

The word "rooster" ends with what letter: R, T, P, or F? *

Submit

Contact Role
Policyholder / Property
Owner
Congressional Office
FEMA / FIMA Leadership
FEMA HQ Staff
FEMA Regional Staff
State / Local Community
Official
Insurance Agent
Real Estate Agent
Lender
NFIP Insurer
Other

FEMA Privacy Office
Privacy Act Statement/e(3) Notice

Privacy Act Statement/e(3) Notice Guidance and Template
The Privacy Act of 1974, 5 U.S.C. 552a, provides protection to individuals by ensuring
that personal information collected by federal agencies is limited to that which is legally
authorized and necessary and is maintained in a manner which precludes unwarranted intrusions
upon individual privacy.
Pursuant to 5 U.S.C. §552a(e)(3), agencies are required to provide what is commonly
referred to as a “Privacy Act Statement” to all persons asked to provide personal information
about themselves, which will go into a system of records (i.e., the information will be stored and
retrieved using the individual’s name or other personal identifier such as a Social Security
number).
Submission Process
All Privacy Act Statements must be reviewed and approved by the DHS Privacy Office.
Components may request a delegation to review and approve their own Privacy Act Statements.
Components must still submit approved Privacy Act Statements to the DHS Privacy Office for
reporting purposes.
Please submit Privacy Act Statements to the Privacy Office for review and approval at
[email protected].
Drafting a Privacy Act Statement
Privacy Act Statements should be written in Plain English, while still adhering to the
requirements of 5 U.S.C. §552a (e)(3). When drafting a Privacy Act Statement for review by the
Privacy Office, include the following elements:
• Authority: The legal authority for collecting the information – statute, executive order,
regulation.
• Purpose: The purpose(s) for collecting the information and how DHS will use it.
• Routine Uses: To whom DHS may disclose the information outside of the Department and
for what purposes.
• Disclosure: Mandatory or Voluntary: Whether providing the information is mandatory or
voluntary. DHS can only make collection mandatory when a Federal statute, executive
order, regulation, or other lawful order specifically imposes a duty on the person to
provide the information; and the person is subject to a specific penalty for failing to
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FEMA Privacy Office
Privacy Act Statement/e(3) Notice

provide the requested information. The effects, if any, of not providing the information –
for example the loss or denial of a privilege, benefit, or entitlement sought as a
consequence of not furnishing the requested information.
Privacy Act Statement versus a Privacy Notice
Privacy Act Statements should only be used for information collections that will be stored in a
Privacy Act System of Records. To include a “Privacy Act Statement” on an information
collection that is not covered by the Privacy Act is misleading.
However, any time information is collected from a form, DHS encourages a Privacy Notice that
describes the same requirements above, in a less formal format.
Collection of SSNs
If the program or form collects Social Security numbers, specific notice regarding the collection,
use, and authorization of Social Security Numbers must be incorporated into the Privacy Act
Statement. This is addressed by adding a sentence to the Privacy Act Statement regarding the
collection of the SSN.
DHS cannot deny a legal right, benefit, or privilege if individuals refuse to provide their SSN
unless the law requires disclosure or, for systems operated before 1 January 1975, a law or
regulation adopted prior to that date required disclosure in order to verify the identity of the
individual.
Before requesting a Social Security number (SSN), even if it will not go into a system of records,
the agency must provide notice to the individual which includes:
• The law or authority for collecting the SSN.
• How DHS will use the SSN.
• Whether disclosure is mandatory or voluntary.

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FEMA Privacy Office
Privacy Act Statement/e(3) Notice

FEMA Privacy Act Statement
Ask the Flood Insurance Advocate a Question Form Privacy Act Statement
Pursuant to 5 U.S.C. § 552a(e)(3), this Privacy Act Statement serves to inform you of why
FEMA is requesting the information on this form.
The information provided by those seeking the assistance from the Office of the Flood Insurance
Advocate (OFIA) assists the OFIA in answering their question and providing guidance the
customer is seeking. Providing any information to OFIA is voluntary and is used to assist
property owners and policyholders and to answer questions related to the NFIP.
AUTHORITY:
FEMA is authorized to collect the information requested on this form pursuant to the following
legal authorities: Under 42 U.S.C. 4033, the FEMA Administrator shall designate a Flood
Insurance Advocate to advocate for the fair treatment of policyholders under the National Flood
Insurance Program (NFIP) and property owners in the mapping of flood hazards, the
identification of risks from flood, and the implementation of measures to minimize the risk of
flood. The NFIP is authorized under 42 U.S.C. 4011 et seq.
A System of Record Notice is found at DHS/FEMA-003 National Flood Insurance Program
Files May 19, 2014 79 FR 28747. DHS/FEMA collects and maintains records and information
regarding applicants, policyholders, prospective policyholders, insurance agents, and other
individuals associated with NFIP. DHS/FEMA needs the information in order to properly
administer the NFIP. The NFIP collects and maintains records of individuals that seek NFIP
policies and/or rate quotes, apply for an NFIP policy, make NFIP insurance claims, appeal flood
insurance claim decisions, and are involved in NFIP administration or marketing efforts.
PURPOSE:
The purpose of this information collection is to solicit inquiries and gather contact information
that will allow FEMA’s Office of Flood Insurance Advocate (OFIA) to promptly and timely
respond to from National Flood Insurance Program policy holders have been impacted by
disasters and Covid-19.
ROUTINE USES:
The OFIA does not intend to disclose any customer personal information outside of DHS.DHS
may need to disclose the information outside of the Department which will be consistent with
DHS/FEMA-003 National Flood Insurance Program Files May 19, 2014 79 FR 28747. The
Department’s full list of system of records notices can be found on the Department's website at
http://www.dhs.gov/system-records-notices-sorns.

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FEMA Privacy Office
Privacy Act Statement/e(3) Notice

CONSEQUENCES OF FAILURE TO PROVIDE INFORMATION:
Providing this information to FEMA is voluntary. However, failure to provide this information
may result in OFIA being unable to respond to an inquiry.

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