Skip to main content

  • Comment Detail

  • Date: 08/29/15
    First Name: Karen
    Last Name: Adams
    Organization: Arizona department of Insurance
    City: N/A
    State: N/A
    Attachment: N/A
    Number: 2015-N-07

  • Comment

    Than you for the opportunity to provide comments.

    I am having difficulty locating the document for review. Would it be possible to provide links to the documents on the "request for comments" page?

    In order to accurately estimate the probability of default on a loan, it is necessary to have information on second and third mortgages tied to the 1st mortgage. Without this information, probability of default on the 1st mortgage may be underestimated and consequently reserves for losses and premium deficiency could be underestimated. Please consider allowing information on the UPB of second and third mortgages to be linked to the first mortgage.