Despite widespread concerns, it does not appear that systematic incentives exist for any participant in the program to underpay on claims. Nor does there presently exist evidence of any such pattern of underpayment. Theories of “systematic underpayment” are inconsistent with the actual data produced by FEMA auditing. We found no persuasive evidence to support the existence either of any general incentive to underpay policyholders or of any practice of doing so. Data from claims operation reviews of “Write-Your-Own” (WYO) insurance carriers – private companies that issue and service NFIP policies – and from the “Direct” program, in fact, show low overall rates of payment errors. If anything, these data indicate that overpayments are more common than underpayments.