USMI submitted a letter to Federal Housing Finance Agency (FHFA) Director Sandra Thompson to provide feedback on the Notice of Proposed Rulemaking (NPR) on “Quality Control Standards for Automated Valuation Models (AVMs).” As sophisticated long-term managers of single family mortgage credit risk, private MIs support a workable regulatory framework for mortgage market participants’ use of AVMs and policies that appropriately balance improvements and efficiencies in the collateral valuation process with the accurate assessment and pricing of risk. In the letter, USMI highlights the following factors to be considered: (1) principles-based approach to quality control frameworks; (2) application to the GSEs; (3) transparency in AVM data; and (4) nondiscrimination and fair lending. Click here to read the letter.
Category: Comment Letters
Letter: Comments to FHFA on GSEs’ Single-Family Mortgage Pricing Framework
Letter: USMI Submits Comment Letter for FHFA’s NPR on “Fair Lending, Fair Housing, and Equitable Housing Finance Plans”
Letter: USMI Submits Letter To DBRS Morningstar on the Proposed Mortgage Insurance (MI) Credit Appendix
Letter: Supplemental Comments & Recommendations to GSE Credit Score Industry Engagement Survey
Letter: Mortgage Insurers Respond to SEC’s Proposed Rule 192
Letter: Joint Trades Letter to House Ways and Means Committee in Support of MI Tax Deduction
Letter: Joint Trades Letter to Senate Finance Committee in Support of MI Tax Deduction
Letter: Statement to Senate Finance Committee Hearing, “The Role of Tax Incentives in Affordable Housing”
USMI submitted a statement for the record to the U.S. Senate Committee on Finance for its July 20 hearing, “The Role of Tax Incentives in Affordable Housing.” USMI writes “that there are tax policies that can be improved in order to help American family achieve the American Dream of homeownership. More specifically, we strongly support S. 3590, the Middle Class Mortgage Insurance Premium Act of 2022, a bipartisan bill introduced by Senators Maggie Hassan and Roy Blunt.” See here for the full letter.
Letter: Statement to House Committee on Ways and Means’ Hearing, “Nowhere to Live: Profits, Disinvestment, and the American Housing Crisis”
Letter: Joint Trades Letter on Enterprise Credit Score Model Framework
USMI submitted a comment letter to the Federal Housing Finance Agency (FHFA) in regards to the implementation of Section 310 of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 (“the Act”). As FHFA prepares to implement the Act, we write to request that it provide additional data, a detailed transition plan that is subject to stakeholder input, and ample time for any transition. This request need not delay FHFA’s decision regarding its review and approval of one or more credit score models, but instead would ensure that the transition to one or more new models is as smooth as possible. See here for the full letter.
Letter: Comments on FHFA’s 2022-2026 Strategic Plan
On March 11, 2022, USMI submitted a comment letter to the Federal Housing Finance Agency’s (FHFA) Acting Director Sandra Thompson on the agency’s draft Strategic Plan for Fiscal Years 2022-2026. USMI supports the overarching goals articulated in the Strategic Plan to: (1) secure the government sponsored enterprises’ (GSEs) safety soundness; (2) foster housing finance markets that promote equitable access to affordable and sustainable housing; and (3) responsibly steward the FHFA’s infrastructure. USMI offered additional recommendations and observations, including that FHFA should work in concert with the Federal Housing Administration (FHA) to ensure that pricing promotes borrower choice and allows the GSEs to advance access and affordability in the housing finance system, and that FHFA should implement policies that allow industry participants and consumer advocate organizations to serve as partners to the GSEs on initiatives that aim to promote equitable housing, address barriers to homeownership, and continue prudent risk management. Read the full letter here.
