Today, CUNA sent this letter with the FHFA in response to its RFI on Fannie Mae and Freddie Mac Credit Score Requirements. CUNA encouraged the FHFA to continue to work to find the right balance between safety and soundness and credit availability for American consumers.

The FHFA is seeking feedback about the operational and competition considerations of changing the Enterprises’ current credit score requirements. The credit scores being evaluated by FHFA and the Enterprises are Classic FICO, FICO 9, and VantageScore 3.0. The Enterprises currently use Classic FICO for product eligibility, loan pricing, and financial disclosure purposes.

CUNA believes FHFA should continue to work with lenders, including credit unions, to improve and promote the housing market. Having a housing finance market that provides liquidity throughout the country requires strong participation by a wide range of lenders, including small lenders and lenders serving rural areas.

Qualified financial institutions and creditworthy eligible borrowers should have fair and equitable access to the financial services offered by the Enterprises. In addition, with regard to the FHFA’s inquiry into credit score requirements, CUNA stressed the importance of an approach that minimizes prescriptive requirements and maximize flexibility for lenders credit unions and other lenders.