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  • Comment Detail

  • Date: 05/22/23
    First Name: Michelle
    Last Name: Mason
    Email: mmason@firstcommercialbk.com
    Organization Type: other
    Organization: First Commercial Bank
  • Comment

    I do not agree with the recent credit score changes and the impact and cost assigned to higher scoring borrowers. It's important to base such decisions on reliable data, and if there is no evidence to support an incrementally higher default ratio within the credit score range of 740 to 780, it raises questions about the necessity of these changes. The CFPB data indeed indicates that credit scores above 720 are generally considered very low risk in mortgage lending.

    While it's commendable that there is a decrease in costs for lower credit scores and lower income households, it seems like there could be a gap in the market for a product designed specifically for moderate-income borrowers. Given the current housing prices, many borrowers with median income find themselves priced out of the market. It's unfortunate that these higher-scoring borrowers are being penalized without apparent justification. Perhaps a more balanced approach that considers the needs of different income groups could better serve the industry and address the affordability challenges faced by median-income borrowers.