| Entities | Federal Home Loan Mortgage Corporation (Freddie Mac) (7) |
| Topics and Issues |
In December 2018, the Federal Housing Finance Agency (FHFA) issued a proposed rule “on the process for validation and approval of credit score models by the Federal National Mortgage Association (Fannie Mae) and the Federal Home Loan Mortgage Corporation (Freddie Mac).” FHFA created a webpage for its Validation and Approval of Credit Score Models regulatory process. In connection with the December 2018, notice, FHFA received 61 comments (credit score pulldown).
CDIA filed a comment (1) urging FHFA to reconsider its proposed prohibition on consumer data provider affiliates submitting scoring models for validation and approval by the Enterprises; (2) encouraging FHFA to consider the potential benefits of a scoring model developed by a consumer data provider affiliate and balance any remaining competition concerns against those benefits; and (3) urged FHFA to consider the range of alternatives to a blanket prohibition for any competition concerns. In particular, CDIA encouraged FHFA to take the approach that the FTC took when it considered limiting costs for credit score disclosures by monitoring the market for credit scores and acting to protect competition if the need arises.