Comments of National Consumer Law Center, Atlanta Legal Aid Society, Inc, Connecticut Fair Housing Center, Consumer Action, Demos, Jacksonville Area Legal Aid, Inc, National Association of Consumer Advocates, U.S. PIRG, and World Privacy Forum regarding Validation and Approval of Credit Score Models.
The undersigned consumer and advocacy groups are pleased to submit the following comments
in response to the Federal Housing Finance Agency (FHFA)’s proposed rule on the process for
validation and approval of credit score models used by Fannie Mae and Freddie Mac, collectively the Government Sponsored Enterprises (GSEs). The proposed rule fulfills the requirement for FHFA to issue regulations governing this issue, as set forth by Section 310 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) of 2018, Pub. L. No. 115-174.