Consumers’ Research has requested that federal agencies terminate partnerships with First Street Foundation and instead rely on Federal Emergency Management Agency (FEMA) maps, according to a letter from the organization. The letter, signed by Executive Director Will Hild, was addressed to multiple U.S. agencies.
According to the letter, Hild argues that First Street’s collaborations with federal entities create a misleading "halo" effect for its Risk/Flood Factor scores on real-estate portals. It references collaborations with the Environmental Protection Agency's (EPA) EJScreen, NASA, and usage by the Federal Housing Finance Agency (FHFA) and Consumer Financial Protection Bureau (CFPB), as well as integrations with Zillow and Realtor.com. The letter highlights consumer complaints reported by local media and the Better Business Bureau (BBB), urging agencies to clarify that non-regulatory tools should not replace FEMA’s legal standards for insurance, lending, or disclosures.
American Stewards reported an example involving a 128-acre Tennessee estate listed at $6.2 million assigned a 9/10 climate-risk score by First Street, while FEMA showed a risk of 1. After complaints, the listing was changed to "off market" with a new value of $401,010. This incident illustrates how such scores can affect online marketplaces and perceived property values. It underscores the need for greater prominence of FEMA data on listings and time-bound remediation pathways when owners provide site-specific evidence like Letters of Map Amendment (LOMAs) or elevation certificates.
The Daily Caller report specifies that Consumers’ Research’s letter targets multiple agencies and emphasizes that First Street’s 1–10 property-level "Risk Factor" labels should not replace FEMA determinations. The report also notes that Realtor.com displays both FEMA and First Street ratings on every listing, while FEMA’s regulatory benchmarks reference 1-in-100 and 1-in-500 flood probabilities, highlighting discrepancies between non-regulatory scoring and statutory standards.
Further cases include North Carolina homeowners facing "10/10 Extreme" labels without flood histories and a Chappaqua, New York couple claiming First Street’s data contributed to a sale price $100,000 below their purchase price three years earlier. American Stewards reported these incidents show an asymmetric consumer burden: owners must disprove broad models lacking granular validation pathways. This pattern supports calls to bar substitution of non-regulatory scores for any official purpose and require transparent error metrics before third-party labels are displayed alongside listings where they may affect demand.
Consumers’ Research is a nonprofit consumer-education organization founded in 1929 in Vienna, Virginia. It positions itself as the nation’s oldest consumer advocacy group focused on informing consumers through research about products, corporate practices, and policies affecting household finances. The organization emphasizes transparency and accountability while engaging media, regulators, and companies to advance consumer welfare.
