Comment Detail

Comment

I am writing to express my views regarding the Loan Level Pricing Adjustments (LLPAs) implemented by Fannie Mae and Freddie Mac. I firmly believe that these adjustments should be based strictly on empirical data regarding risk factors, allowing for a more transparent, equitable, and predictable mortgage market.

In order to ensure fairness and objectivity in the mortgage industry, it is crucial that LLPAs reflect only the documented historical risk factors that both Fannie Mae and Freddie Mac closely monitor for loan performance. This approach will ensure that borrowers are charged solely and directly based on the risk they present, thus contributing to a more balanced and fair lending environment.

Over-reliance on non-data-driven factors in pricing adjustments could inadvertently penalize borrowers who might not genuinely represent a higher risk. A strictly data-based approach towards LLPAs will not only enhance the credibility and predictability of these adjustments but also uphold the integrity of the mortgage market.

I trust that the FHFA will give due consideration to these views and strive to make the LLPAs more data-driven, transparent, and fair for all stakeholders in the mortgage industry.

Thank you for your attention to this important matter.