CHLA Requests Amended Timeline For New Credit Score Reporting Process

CHLA Requests Amended Timeline For New Credit Score Reporting Process

Written By: Joel Palmer, Op-Ed Writer

The Community Home Lenders of America (CHLA) wants the Federal Housing Finance Agency (FHFA) to alter its previously announced implementation schedule for changes in the credit score reporting process.

In a letter sent last week to FHFA, CHLA urged the regulatory agency to begin with process using only VantageScore, while deferring use of FICO 10T to a later phase.

FHFA announced its timeline in March for replacing the Classic FICO credit score model with FICO 10T and VantageScore 4.0. The proposed timeline indicates that both scores will be incorporated into capital and pricing simultaneously in the fourth quarter of 2025.

Once implemented, lenders will be required to deliver both FICO 10T and VantageScore 4.0 credit scores with each loan sold to the enterprises. The new process also includes a transition from requiring three credit reports to requiring two for single-family loan acquisitions.

The process is part of an initiative to modernize credit score model requirements, which began in 2014 following passage of the Economic Growth, Regulatory Relief, and Consumer Protection Act. A section of this law required FHFA to create a process for validating and approving credit score models.

What appears to be a contributing issue is a credit report price increase FICO announced late last year and imposed on lenders in January.

The price increase affected lenders differently based on size, according to the National Consumer Reporting Association (NCRA). Fair Isaac (FICO) established three pricing tiers. The wholesale price increase was only 10 percent for the top tier of approximately 46 lenders. FICO increased its credit reporting price by 200 percent for six lenders in a middle tier. The remaining lenders were hit with a 400 percent price increase, according to NCRA.

“This is a paradigm shift in the pricing structure for credit scores and is being dictated to the mortgage credit reporting industry from all three national credit bureaus and/or FICO,” NCRA wrote in a letter last November to mortgage lenders.

CHLA added in its letter to FHFA that the agency “should not expand FICO’s authority to use alternative credit score models on enterprise loans until the 400% price hike and discriminatory application is addressed.”

CHLA added that stakeholders need more time to provide feedback, and that specific stakeholders, including the Federal Housing Administration (FHA), Veterans Affairs (VA), and Government National Mortgage Association (Ginnie Mae), should be better engaged in the process “to foster collaboration and align goals in the credit score reporting process.”

In a previous letter written to FHFA in late June, the CHLA and several industry stakeholders wrote: “FHFA cannot fully anticipate the conclusions and observations that will arise from the stakeholder analysis of the historical data and should not rush to meet a firm deadline at the risk of creating widespread operational challenges. Already, we expect that one external complication that could affect the timeline is government agency adoption of the new scoring models.”

The letter further stated that Fannie Mae and Freddie Mac may need time to advise the government lending programs, to assist with simultaneous policy updates to maintain existing underwriting pathways between programs. Otherwise, “there could be significant consumer confusion and operational backlog, should a prospective borrower change loan programs.”

The parties that signed the June letter indicated that they wanted FHFA to adjust the credit score policy implementation plan to include:

  • 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

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.


About the Author

As an NAMU® Opinion Editorial Contributor, Joel Palmer is a freelance writer who spent 10 years as a business and financial reporter and another 10 years in marketing for the insurance and financial services industries. He regularly writes about the mortgage industry, as well as residential and commercial real estate, investments, and retirement income planning. He has also ghostwritten books on starting a business, marketing, and retirement income planning.


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