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  • Comment Detail

  • Date: 03/17/19
    First Name: Paul
    Last Name: Weinstein Jr
    Organization: Progressive Policy Institute
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA98

  • Comment

    fAlfred M.Pollard
    GeneralCounsel
    Attention: Comments/ RIN 2590—AA98
    Federal Housing Finance Agency Eighth Floor
    400 SeventhStreet SW,
    Washington, DC 20219

    Dear Mr. Pollard:

    The purpose of this letter is to respond to FHFA's request for comments on the Validation and Approval of Credit Score Models. I applaud the agency for trying to expand homeownership for more Americans. However, I urge some caution regarding this rule. Specifically:

    • To ensure competition, encourage innovation, and prevent abuse, a credit score provider must be independent from the suppliers of credit data, otherwise the new rule may simply trade one dominant player for another;
    • The FHFA should enable opportunities to innovate using alternative, non-CRA data;
    • Pilots should be conducted prior to any large scale changes in the system to prevent un-intended
    consequences.

    Thank you for your consideration.

    Sincerely,

    Paul Weinstein Jr
    Senior Fellow
    Progressive Policy Institute
    1200 NewHampshire Avenue, NW
    Washington,DC 20036