Resource Filter: Letters

Comment Letter: Housing Trade Groups File National Mortgage Database

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The following letter was delivered to the Federal Housing Finance Agency:

 

May 16, 2014

Alfred M. Pollard, General Counsel
Attention: Comments/2014-N-03
Federal Housing Finance Agency
400 Seventh Street S.W.
Washington, D.C. 20024

Via Email at RegComments@fhfa.gov

RE: 2014-N-03
Dear Mr. Pollard:

The undersigned associations appreciate the opportunity to comment on the Notice of revision to an existing system of records (2014-N-03) regarding the National Mortgage Database (the “NMDB”) under development by the Federal Housing Finance Agency (FHFA) and the Consumer Financial Protection Bureau (CFPB). The NMDB has two stated purposes: to facilitate mandatory reporting under the Housing and Economic Recovery Act of 2008 and to conduct “research, performance modeling and examination monitoring.” In addition to borrower records based on credit repository data, the database will include results of ongoing borrower surveying. Records will be matched with records within other datasets and then personal identifiers will be “deidentified” before the NMDB is used for research. This matching function makes the NMDB unique and uniquely valuable as a research tool.

In July 2013, representatives of FHFA, the CFPB and Freddie Mac presented at the International Conference of Collateral Risk: Moderating Housing Cycles and their Systemic Impact. The presenters explained that the NMDB is being set up as “a public good” that is needed because existing databases (HMDA, LPS McDash , CoreLogic and NY Fed Equifax) are not fully representative, and in the case of HMDA, also do not report data until 9-21 months after a mortgage is originated. For some, the cost of obtaining information from the existing databases is prohibitive.

By closing these existing data gaps, the NMDB will serve as a valuable research tool that should be made broadly available for housing finance research and analysis. However, it is currently contemplated that access to the NMDB will be allowed only for certain employees of federal government agencies, reserve banks and Fannie Mae and Freddie Mac (“the Enterprises”). The undersigned believe that it is inappropriate and unnecessary to restrict access to the NMDB in this way. The NMDB will facilitate important undertakings within the private sector, including market analysis, product development and evaluation of credit risk standards. It will also enable third parties to assess work done by federal agencies or the Enterprises based on the NMDB, and will promote robust policy discussions and help to drive sound outcomes. Consumer identifying information will be removed from the NMDB, thus minimizing any potential threat to consumer privacy. However, if FHFA or the CFPB has lingering concerns about privacy issues, a simple user agreement to refrain from reverse engineering records would provide added protections.

The undersigned appreciate your consideration of this important issue. Feel free to contact any of us if we may be of further assistance.

 

Very truly yours,

Mortgage Bankers Association
Attn: Stephen A. O’Connor (soconnor@mba.org)

National Association of Home Builders
Attn: David L. Ledford (dledford@nahb.org)

U.S. Mortgage Insurers
Attn: Rohit Gupta (rohit.gupta@genworth.com)
Adolfo F. Marzol (adolfo.marzol@essent.us) .

 

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Letter: USMI Urges Support of Johnson-Crapo

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USMI delivered the following letter to members of the Senate Banking Committee:

USMI Header 750
April 28, 2014

 

The Honorable Tim Johnson
Chairman
Senate Banking Committee
136 Hart Senate Office Building
Washington, DC 20510

The Honorable Mike Crapo
Ranking Member
Senate Banking Committee
239 Dirksen Senate Office Building
Washington, DC 20510

 

Dear Chairman Johnson and Ranking Member Crapo:

With the Senate Banking Committee set to consider the Johnson-Crapo comprehensive housing finance legislation, the members of U.S. Mortgage Insurers – USMI – applaud the Committee leadership for their bipartisan work on this important bill, and urge the Members of the Committee to support it.

The Johnson-Crapo bill reflects several compelling goals.  There is a growing consensus that the current housing finance system, dominated by government support, is unsustainable.  There is also widespread recognition that private capital, and not the taxpayers, should bear more of the risks of losses from another housing downturn.  Reform should be accomplished in a manner that keeps mortgage financing affordable and accessible to creditworthy borrowers across the economic spectrum.

We are pleased that the bill recognizes the important role of private mortgage insurance in ensuring that creditworthy borrowers continue to have access to affordable and sustainable mortgages, protecting taxpayers, and serving lenders of all sizes.

We look forward to working constructively with the Committee and other policymakers as the process moves forward to help build a well-functioning housing finance system backed by private capital.

 

Sincerely,

Rohit Gupta, President and CEO of Genworth Mortgage Insurance (Co-Chair)
Adolfo Marzol, Executive Vice President of Essent (Co-Chair)

cc: Members of Senate Banking Committee

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Letter: To FHFA regarding GSE Loan Limits

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March 20, 2014

Federal Housing Finance Agency
Office of Policy Analysis and Research
Constitution Center
400 Seventh Street, SW., Ninth Floor
Washington, DC 20024
Attn: No. 2013-N-18
Submitted via email at loanpurchaselimitinput@fhfa.gov

Re: Fannie Mae and Freddie Mac Loan Purchase Limits: Request for Public Input on Implementation Issues (2013-N-18)

Ladies and Gentlemen:

The undersigned organizations appreciate the opportunity to comment on the Federal Housing Finance Agency (FHFA) proposal to reduce the loan purchase limits for Fannie Mae and Freddie Mac (“the Enterprises”).

The nation’s housing markets are on a slow and cautious recovery. The credit box for home lending is exceedingly tight with the average FICO score for a loan sold to the Enterprises at 753 and the average loan-to-value ratio at 70 percent. As Congress considers comprehensive housing finance system reform, we strongly support maintaining the Enterprises’ current conforming and high-cost loan purchase limits at the levels determined by the Housing and Economic Recovery Act (HERA) of 2008 or $417,000 and $625,500 respectively. For areas with loan purchase limits between $417,000 and $625,500, we also believe that you should maintain the current formula for tying the maximum limit to median home prices in those areas.

Congress is making incremental progress on legislation to reform the housing finance system. Plans under consideration in both chambers of Congress directly address loan limits. Setting loan limits is a significant component of housing policy and, as such, is best left to Congress’ discretion, especially while many of the nation’s housing markets remain fragile. In addition, we note that while this proposal is in part premised on shrinking the government’s footprint in the mortgage market, the reduction of the Enterprises’ loan purchase limits could simply shift borrowers to other government-insured programs.

Thank you in advance for your consideration of this important issue. We strongly support FHFA’s efforts to stabilize and strengthen the mortgage market, but we believe that the proposed reductions will have the opposite effect. Should you have questions or wish to discuss any aspect of these comments further, please contact any or all of our organizations.

Sincerely,

Asian Real Estate Association of America (AREAA)
Community Mortgage Lenders of America
Independent Community Bankers of America
Leading Builders of America
Mortgage Bankers Association
National Association of Hispanic Real Estate Professionals (NAHREP)
National Association of Home Builders
National Association of REALTORS®
National Community Reinvestment Coalition
U.S. Mortgage Insurers

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