NCLC comments on two provisions of the Federal Housing Finance Agency’s proposed rule that would amend the Enterprise Regulatory Capital Framework for Fannie Mae and Freddie Mac. The comments express support for
1. A proposal to use an average of borrowers’ two credit scores as the representative credit score for single-family mortgages instead of the lower of two credit scores; and
2. A proposal to assign a representative credit score of 680 instead of 600 for borrowers who have no credit score.