Comment Detail
Date: 04/26/23 First Name: Jordan Last Name: Yost Organization: N/A City: N/A State: N/A Attachment: N/A Number: RIN-2590-AB29 Comment
Thank you for taking the time to accept and read comments on this proposed rule. I found section II (background) very insightful. Though some of the examples (eg: Minneapolis gap at 50% points) were cherry picked to build your case, I found the overall sentiment to be an accurate description of the difference between White, American home ownership vs Minority, American home ownership.
However, the proposed rule does not address the root of these issues. Rather than continuing to rely on Freddie & Fannie to do the right thing, you should propose better zoning laws within cities and states. Affordable housing, public housing, and primary-residence housing are just a few of the ways you can get home ownership into the hands of the underserved. Allowing applicants and borrowers the option to not self-select ethnicity/race (M. SECTION 1293.31 REQUIRED ENTERPRISE DATA COLLECTION AND REPORTING) is a small, but good step in fighting discrimination against underserved communities. But I'll say it again, it's not enough. Despite removing that field, there will still be lenders that discriminate based on the applicant's name. I'm sure some of your studies found that to be equally true as when a lender discriminates based on the ethnicity listed in the form.
Please do not pass this rule. It falls short of real change and only strengthens the stranglehold of Freddie/Fannie on the mortgage landscape. Consider zoning law changes instead. Create a rule to enact real change instead of adjusting fields on a piece of paper.
Sincerely,
Jordan