Comment Detail
Date: N/A First Name: pavan Last Name: agarwal Email: pavan@swmc.com Organization Type: fannie mae Organization: sun west mortgage company inc Comment
Presently Freddie and eventuaave a free hand in setting g fees per lender . The result has been irrational g fees. The fhfa should define a standard g fee matrix that takes into consideration the seller servicer's experience, delinquencrati, net worth, service to minority and underserved communities, and past performance.
Arbitrary and discriminatory g fees results in overcharging to consumers and can potentially result in disparate impact. For example if lender a serves
mostly minority communities while lender b does not yet if lender A has a higher g fee even though lender a and lender b are equivalent risks, the minority customers of lender a would be getting higher rates than the non minority customers of lender b.
This troubling scenario is likely happening today.