Letter: Comment to FHFA on the Notice of Proposed Rulemaking (NPR) on “Quality Control Standards for Automated Valuation Models (AVMs)”

August 28, 2023


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.