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  • Comment Detail

  • Date: 05/16/23
    First Name: Jason
    Last Name: Ashe
    Email: jason.ashe@rate.com
    Organization Type: other
    Organization: Guaranteed Rate

  • 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.
    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.