Comment Detail

Comment

We urge FHFA to consider how any change to credit score requirements aligns or fails to align with the
Enterprises’ Duty to Serve goals to address the concerns of low- to moderate-income (LMI) households and to
improve their services for those households.

RMI supports FHFA’s goal to foster innovation in credit scoring. But we believe that accounting for energy cost risks in underwriting for LMI and non-LMI borrowers alike would have more meaningful and wider spread risk mitigation impacts than marginal improvements in credit score requirements. RMI is developing a proposed framework for the Enterprises to leverage available home energy data sources and seamlessly integrate this information into their automated underwriting systems. We would welcome the opportunity to discuss this approach directly with the FHFA and Enterprises in order to engage in more targeted research and innovation that would result in the most useful and impactful outcomes.

As always, RMI would like to extend its technical expertise, stakeholder facilitation, and other skillsets to support FHFA and the Enterprises in their efforts to continue improving processes and product offerings, both under Duty to Serve and more broadly. Please contact Jacob Corvidae at jcorvidae@rmi.org if you would like to discuss the contents of this letter or our offer to support your efforts further.

Our three comments and associated recommendations addressing specific questions laid out in the RFI are included in the attached 5-page document.