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  • Comment Detail

  • Date: 05/18/23
    First Name: Jeffrey
    Last Name: Bochsler
    Email: jeff.bochsler@rate.com
    Organization Type: other
    Organization: Guaranteed Rate, Inc.

  • Comment

    The additional LLPA fees charged to borrowers with higher credit scores to subsidize those with lower credit scores creates a moral hazard. I love the intention and believe I understand well enough the social construct going on for decades / centuries leading to certain races and classes left with much lower average credit scores. It's important to find solutions for these classes and races. Yet, this isn't a solution. It only leads higher credit score individuals to consider missing one credit card payment, paying the $35 fee, and ultimately getting a better mortgage rate offering as a result. It's certain, this will be a game people play, and mortgage loan officers recommend, if their clients are to get better rates by doing this strategic credit card payment miss a few months before purchase. Thus, I'm very much in favor of finding ways to restructure the systems at play, holding many back, but this LLPA adjustment, doesn't look to be one that won't be abused and hurt everyone in the end.