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.
USMI joined a coalition of industry trade associations and consumer advocate groups in sending a joint trade letter to the Federal Housing Finance Agency (FHFA) in response to the agency’s March 23 announcement regarding the implementation plan for the adoption of the FICO 10T and VantageScore 4.0 credit score models, as well as the bi-merge credit reporting policy, by Fannie Mae and Freddie Mac. The coalition recommends that the credit score policy implementation plan should be adjusted to include a comprehensive, transparent, and iterative stakeholder engagement process, as well as robust data transparency, specifically including the release of long-term historical datasets for Classic FICO, FICO 10T, and VantageScore 4.0. The organizations also call for the FHFA to provide a recalibrated timeline that accommodates data analysis and modeling, as well as stakeholder feedback on the costs, complexity, consumer impact, and policy implications of the transition. Click here to read the letter.
The letter’s signatories include:
American Bankers Association, Center for Responsible Lending, Community Home Lenders of America, Consumer Bankers Association, Credit Union National Association, Housing Policy Council, Independent Community Bankers of America, Leading Builders of America, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Association of Home Builders of the United States, National Association of REALTORS®, National Housing Conference, Reinsurance Association of America, Securities Industry and Financial Markets Association, and Structured Finance Association.
USMI joined a coalition of housing finance organizations including the American Bankers Association (ABA), Housing Policy Council (HPC), and the Independent Community Bankers of America (ICBA) in responding to one element of the Federal Housing Finance Agency’s (FHFA) Notice of Proposed Rulemaking (NPR) on enhancements to the Enterprise Regulatory Capital Framework (ERCF). The organizations raised concerns regarding the method of calculating a borrower’s representative credit score once the government-sponsored enterprises (GSEs) migrate to the bi-merge credit report requirements. The coalition recommends that loan-level GSE data from 1999 forward should be published sooner than 4Q 2023 to allow for the necessary analysis and impact assessment ahead of the proposed implementation in 1Q 2024. In addition, the organizations call for FHFA to work more closely with the industry to fully assess operational and regulatory compliance considerations for mortgage market participants, including for the notices and disclosures required under the Fair Credit Reporting Act (FCRA). Click here to read the letter.
USMI submitted a letter for the record for the U.S. Senate Committee on Finance’s March 7 hearing titled, “Tax Policy’s Role in Increasing Affordable Housing Supply for Working Families.” USMI has long supported the tax provision allowing a deduction for MI premiums paid in connection with a mortgage on a qualified residence and commends the bipartisan work on the Middle Class Mortgage Insurance Premium Act to make the deduction permanent and expand taxpayer eligibility. Since 2007, the MI deduction has been a powerful tool in prudently promoting homeownership for low- and moderate-income (LMI) families and has been claimed over 43 million times by qualified homeowners for an aggregate $61.6 billion in tax deductions. Click here to read the letter.
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.