Resource Filter: Letters
Letter: Joint Letter to the FHFA on Credit Score Implementation
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.
Letter: Supplemental Comments & Recommendations to GSE Credit Score Industry Engagement Survey
Letter: Joint Trade Letter to FHFA on Proposed Enterprise Regulatory Capital Framework (ERCF)
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.
Letter: Mortgage Insurers Respond to SEC’s Proposed Rule 192
Letter: Statement for the Record for U.S. Senate Committee on Finance’s hearing, “Tax Policy’s Role in Increasing Affordable Housing Supply for Working Families.”
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.
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: USMI Calls for Senate Finance Committee to Co-Sponsor the Middle Class Mortgage Insurance Premium Act of 2022
USMI sent letters to members of the Senate Finance Committee encouraging them to co-sponsor the Middle Class Mortgage Insurance Premium Act of 2022, introduced by Senator Maggie Hassan (D-NH) and co-sponsored by Senator Roy Blunt (R-MO). USMI writes, “This important bipartisan legislation would expand eligibility for and make permanent the tax deduction for MI premium payments for borrowers who put less than 20 percent down to purchase their home and qualify for financing thanks to private MI or government-backed MI through the Federal Housing Administration (FHA), the U.S. Department of Veterans Affairs (VA), or the U.S. Department of Agriculture (USDA).” Read our letters to Chairman Ron Wyden and Ranking Member Mike Crapo.
