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  • Comment Detail

  • Date: 05/08/23
    First Name: ELIZABETH
    Last Name: BURKHOLDER
    Organization: Altitude Mortgage Corporation
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AB29

  • Comment

    I have been in the mortgage business since 1981. I am primarily involved in underwriting and loan process and procedures. THERE IS NO OBJECTIVE WAY TO ARRIVE AT A 45% DTI. To set an arbitrary number like 45% will create just as much bias as we have now. It is clear that the number can be manipulated and if it will be subject to audit later this is a no win situation. On any given day 10 underwriters can arrive at 10 different ratios for the same loan. This concept already doesn't work in the Mortgage Insurance world. And if I can manipulate ratios for SOME borrowers that might have excellent credit and higher income (higher residual) or any other borrower that I choose then how is that fair? LTV and FICO score are OBJECTIVE standards. Loan type (cash out etc) is an objective standard. DTI RATIO IS NOT OBJECTIVE.