| Entities |
In June 2023, a group of financial association trades wrote a letter to FHFA on the Administration’s move to bi-merge from a bi-merge. In the letter, the groups wrote that “…the transition…will occur in a multi-stage process that does not adequately address the far-reaching impacts, significant costs, and immense operational complexity of the policy changes.” The letter “urge[d] FHFA to reformulate the proposed timeline to provide sufficient time and an adaptable structure that will permit stakeholder feedback to be considered and incorporated. A disciplined and orderly transition will minimize risk to the stability of the housing finance system.”
The letter asked for
- A comprehensive, transparent, and iterative stakeholder engagement process
- Robust data transparency, specifically including the release of long-term historical datasets for Classic FICO, FICO 10T, and VantageScore 4.0, that allow for analysis of the impacts of the changes and the design of new models to support the wide array of business functions that will be affected; and
- A recalibrated timeline that accommodates both data analysis and modeling as well as a stakeholder engagement process that considers the costs, complexity, consumer impact, and policy implications of the transition.
The letter was signed by the 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, Structured Finance Association, and U.S. Mortgage Insurers