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  • Comment Detail

  • Date: 03/21/19
    First Name: Terry
    Last Name: Clemans
    Organization: National Consumer Reporting Association
    City: N/A
    State: N/A
    Attachment: View Attachment
    Number: RIN-2590-AA98

  • Comment

    Alfred M. Pollard, General Counsel
    Federal Housing Finance Agency - FHFA
    400 7th Street NW, 8th Floor
    Washington, DC 20219

    Re: Comments/RIN 2590-AA98
    Proposed Rule – Validation and Approval of Credit Score Models

    Dear Mr. Pollard:
    On behalf of the National Consumer Reporting Association (NCRA), please find attached our response regarding the proposed rule on the Validation and Approval of Credit Score Models.

    The NCRA is a national trade organization founded in 1992, comprised of consumer reporting agencies and associated professionals who provide products and services to hundreds of thousands of mortgage lenders, property managers, landlords and credit grantors. NCRA's membership includes three out of every four mortgage credit reporting agencies in the United States that produce credit reports for mortgage lending, which meet the requirements of Fannie Mae, Freddie Mac, and HUD, and many of the nation’s largest resident screening companies.

    We greatly appreciate the FHFA taking the time to carefully evaluate the credit score models available to the mortgage industry and how those scores could impact the efficiencies of the American mortgage market. We applaud the ability of the FHFA to truly understand the complexities of this industry and appreciate the opportunity to provide feedback on the proposed validation and approval processes. We are available to the FHFA should any further questions or added comments about any of our responses be required.

    Sincerely,
    Terry W. Clemans
    Executive Director