Removing Barriers Blog

CUNA Comments on the FHFA’s Proposal on the Validation and Approval of Credit-Score Models
Posted March 21, 2019 by CUNA Advocacy

Today, CUNA filed its comments with the Federal Housing Finance Agency on its proposed parameters for the Enterprises Validation and Approval of Credit Score Models. The proposal is in direct response to language in S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act, designed to increase credit score competition in the mortgage market. CUNA’s comment noted that increased market competition in the credit-score industry could be beneficial to both consumers and lenders because it can improve efficiency, decrease pricing, and potentially expand the market of consumers for mortgage products. The comment also acknowledged, however, that the frequent modification of the GSEs credit-scoring models or a requirement that they use multiple models at the same time could discourage competition in the lending market by increasing costs for smaller lenders less capable of quickly and cost-effectively absorbing those changes into their own underwriting systems or paying the resulting increased prices to access the systems of the third-party vendors they rely upon. Ultimately,

CUNA acknowledged the FHFA’s recognition of the need for cost-benefit analysis as a core component of its proposed validation and approval process.   But the comment expressed concern about the adequacy of the proposed cost-benefit analysis because it only vaguely, if at all, referenced lender implementation costs as a factor for consideration. Going forward, CUNA urged the FHFA to adopt a proposal that directly required lender implementation costs to serve as a consideration in the analysis.