Joint Comment Letter on National Survey of Existing Mortgage Borrowers

American Bankers Association

American Financial Services Association

American Land Title Association

Consumer Bankers Association

Consumer Mortgage Coalition

Credit Union National Association

Housing Policy Council of the Financial Services Roundtable

Independent Community Bankers of America

Mortgage Bankers Association

National Association of Federal Credit Unions

January 11, 2016

 

 

Federal Housing Finance Agency Eighth Floor

400 7th Street, S.W. Washington, D.C.  20219  RegComments@fhfa.gov

 

Re:       Proposed Collection; Comment Request

National Survey of Existing Mortgage Borrowers

 

Dear Federal Housing Finance Agency:

The undersigned trade associations appreciate this opportunity to comment jointly on the Federal Housing Agency’s (“FHFA”) proposed collection of information relating to the National Survey of Existing Mortgage Borrowers (“NSEMB”), a periodic, voluntary survey of individuals who currently have a first mortgage loan secured by single-family residential property. The survey is, in effect, an updated version of FHFA’s existing National Survey of Mortgage Borrowers.

 

According to the proposal, the collection of information will use a questionnaire consisting of approximately 80 to 85 questions intended to elicit information from mortgage borrowers about their loans.  The data from the survey is to be included in a National Mortgage Database (“Database”) project which, when complete, will include detailed information about more than 10 million borrowers.

 

The stated goal of the Database is to support policymaking and research efforts to understand emerging mortgage and housing market trends. We believe it is appropriate for the Government to better understand the residential mortgage markets, as greater understanding of the current trends and forces impacting homebuyers is critical to the development of policies that foster a safe and sound marketplace.

 

We are concerned, however, that the Database (1) is overly extensive; (2) poses a significant danger to consumer privacy through reidentification; and (3) is duplicative of other databases. As such, we believe the Database should not be introduced until several steps are taken. These steps include consultation with the Consumer Financial Protection Bureau (“CFPB”) to ensure that the FHFA and CFPB data cannot bresult in reidentification of consumers.  The steps should also include soliciting additional input on the survey topics and questions.  We understand that FHFA is required by law to survey and collect data, but we strongly urge FHFA to make consumer privacy and data collection efficiency its top considerations as this survey develops. FHFA’s proposal mentions that FHFA is required by statute to “compile a database of . . . mortgage market information to be made available to the public.” This implies that the new survey data will be public at least in some part... (continue reading)