MBA Joint Letter to FHFA on Credit Score Implementation

On behalf of 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, we appreciate the opportunity to provide stakeholder

feedback in response to the Federal Housing Finance Agency’s (“FHFA”) announcement on March 23, 2023 of an 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 (collectively “the Enterprises”).