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  • Comment Detail

  • Date: 03/18/19
    First Name: Simone
    Last Name: Griffin
    Organization: HomeFree-USA
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA98

  • Comment

    Since HomeFree-USA was launched in 1995, we've met hundreds of thousands of families who were excited about becoming homeowners and willing to adjust their lifestyle and finances so they too could be part of the American Dream. Most were eventually able to purchase a home but many could have been there sooner had the credit scoring model reflected the way they actually manage money. We know FHFA is fully aware of the discrepancies and working hard to create a balanced marketplace for all homebuyers. HomeFree-USA strongly encourages FHFA to heed Congress' call for increased competition in credit scoring models, including all companies that have demonstrated capacity to do so, regardless of the entity they are owned by. Not significantly expanding access to credit, including by allowing competition in the scoring models, will continue to leave millions of low-credit-risk families out on the proverbial street.

    HomeFree-USA and its nationwide network of nonprofit partners strongly believe in the legislation supporting competition in the credit scoring space. We ask that you ensure the expansion needed is executed in the manner that’s aligned with the true way Americans manage their money, which is not fully recognized via FICO. As a result, it has been reported that over 40 million Americans remain locked out of the homeownership process, in spite of being at low-risk of default. Everyday in our offices we work with people whose financial mechanisms have to be adjusted to meet the FICO requirements - not because they're not already managing money well, but because they're not doing so based on the traditional credit model. That model does not serve a wealth building philosophy, and is not necessarily better for our clients. Yet, being that is the only model allowed for homeownership purposes, our families are required to adjust, which in turn delays or denies their ability to qualify for a mortgage. After reviewing their finances, our Homeownership Advisors can clearly see that they're a low-risk borrower, yet the current FICO model won't reflect such. That's a loss for the homebuyer and lender.

    We thank you for your consideration in this manner, and look forward to seeing the significant number of financial lives changed for the better as a result of your adjusted policy position.