The Consumer Federation of America (CFA) strongly opposes passage of S. 1926, the Homeowner Flood Insurance Affordability Act. Most people would assume that a consumer group such as CFA would seek lower insurance rates for consumers. And, indeed, we do try to achieve that, consistent with reasonable profits for insurers. In fact, for years we have pushed tor federal actions to lower flood insurance rates such as through reducing the excessive costs of the Write Your Own Program and passing on the savings to policyholders.