Comment Detail

Comment

The proposed increases in the G-Fee's are regressive and will distort the cost of credit in the marketplace. Of particular concern are the loan-level adjustments across LTV/score risk groups. Credit scoring is, at best, a crude tool to determine a borrowers credit worthiness, and their potential default risk. Yet, these proposed increases will only further distort loan pricing based upon a number that is known to be susceptible to unreliable reporting, credit fraud, errors, etc. Placing such a heavy and disproportionate "toll" upon a borrower that has the misfortune of having a medical collection or a misreported account history should not be accepted by the industry as "the way it is". We can do better. These proposed increases only further distort credit costs based upon unreliable data to the detriment of the consumer.