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  • Comment Detail

  • Date: 05/12/23
    First Name: Jane
    Last Name: Greeson
    Organization: Pinnacle Financial Partners
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AB27

  • Comment

    The phasing from traditional FICO scoring with tri-merge reports to the new FICO scoring models using bi-merge reports and then shift to tri-merge credit reports using the new scoring models to then choosing our "method" of averaging the loan's representative score is a concern for many reasons. Adoption of the new scoring and averaging methods will be challenging. How will we choose the 'best' averaging method for our region? How will we compete with other Mortgage lenders in our footprint? How is this fair lending? If someone can go to the Bank next door and receive a better price for the same loan parameters and credit profile we reviewed, but because the competitor used a FICO averaging method that happens to be more favorable; then consumer gets a better price and closes their loan with the competitor. It's difficult enough to explain the mortgage process and explain the pricing to customers today. How will the future look for Lenders and consumers using this proposed model of choosing your own averaging method? Of additional concerns are personnel training, procedure implementation and tracking. New scoring models are welcome. I just ask that we please make methodology for choosing (or averaging) the representative score simple and straightforward for Lenders and consumers alike. Please also define one method that all Mortgage Lenders are expected to use so we are on a level playing field with our competitors in the future, as we are today.