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  • Comment Detail

  • Date: 05/02/23
    First Name: Bryan
    Last Name: Glenn
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AB29

  • Comment

    When I began my banking career in the early 1980s banks were still making home mortgage loans almost exclusively to well-heeled borrowers with perfect or near perfect credit.

    I championed mortgage programs that significantly broadened such lending to those that spanned the credit spectrum. I worked hard to eliminate discrimination practices and “good “ol boy” pricing exceptions. Rates were dictated by the borrower’s credit worthiness and ability to repay, regardless of the borrower’s race or gender, or familiarity with the bank or a specific lender.

    I also championed programs that sought to educate borrowers on the credit system and prudent borrowing. I wanted to make mortgage loans to people who for a myriad of reasons had been locked out of this previously. Finally, all approval practices and rate determination policies had to be grounded and tied to rigorous analysis that was likewise tested by regulators. Should preferential treatment be determined during an examination, regulators would have imposed stiff and deserved penalties.

    So the notion of a single minority female with a 749 FICO paying additional fees on her mortgage to lower the rate for a 580 FICO white male is abhorrent to me. And it should be abhorrent to everyone including this agency.

    The rate a borrower should receive should be priced competitively and based solely on that borrower’s credit worthiness and ability to repay. Regardless of intention, to do otherwise smacks of unfair and discriminatory lending practices.