AFFIDAVIT OF FEMA WHISTLEBLOWER #1
I,

being duly sworn, do hereby depose and state the following:

1.

I am presently

years old and reside in

.

2.

I worked for OST, Inc. (“OST”), in connection with the Federal Emergency

Management Agency’s (“FEMA”) Hurricane Sandy Claims Review (“SCR”) process from
approximately September 2015 to January 2016.
3.

My job title while employed in connection with the SCR was flood manager, and

my primary responsibilities included supervising desk auditors and reviewing desk auditor’s
initial results.
4.

I have approximately 20 years’ experience evaluating and adjusting residential

property damage in connection with insurance claims. I have adjusted and/or reviewed
approximately 15,000 of claims during that time.
5.

My qualifications for my work on the SCR include approximately 30

certifications for disaster relief programs and I am a flood certified adjuster.
6.

I did adjust claims on behalf of FEMA’s Write Your Own (“WYO”) insurers in

connection with Hurricane Sandy before my employment in connection with the SCR.
7.

I reviewed approximately 1,000 flood insurance claims during my employment on

the SCR.
8.

The SCR is deigned to systematically underpay homeowners.

9.

While reviewing claims for the SCR, I received instructions from my superiors at

OST and from FEMA managers to exclude from the payment recommendations items that are
covered under FEMA’s Standard Flood Insurance Policies (“SFIP”).

 10.

While reviewing claims for the SCR, I also received instructions not to conduct a

comprehensive evaluation of claims assigned to me in order to identify each item of property
damage subject to insurance coverage, but rather was told to use software developed for the SCR
by McKinsey & Company (“McKinsey”) that produced a range of expected values for each
claim based on the property’s square footage and approximate qualify of construction. I was
directed to tailor my evaluation to fall within this range even if I identified additional covered
damage that warranted insurance coverage.
11.

If I submitted a recommendation for payment on a claim that exceeded the range

generated by the McKinsey threshold software, FEMA would not approve it and directed me to
have the desk auditor revise the findings to fit within the threshold generated by the McKinsey
software.
12.

Other reviewers received these same instructions, which reflected the SCR’s

general operating procedure. The express purpose of these instructions was to limit the
payments made on each claim that I reviewed.
13.

Many other reviewers working for the SCR lacked significant experience

evaluating flood insurance claim damage. Many were not FEMA flood certified.
14.

Other reviewers working for the SCR had worked for WYO insurers adjusting

Hurricane Sandy claims before working for the SCR.
15.

I left the SCR because I believe that it was not reviewing claims in accordance

with accepted industry procedures or the SFIPs’ requirements. Rather, it was an elaborate
process designed to justify minimal payments to policyholders irrespective of the actual merits of
their claims.

 I declare under penalty of perjury that the information contained in this affidavit is true
and correct to the best of my current knowledge and belief.