Because the cost of private mortgage insurance by definition falls on lower-wealth borrowers, the PMIERs have as much of an impact, if not more of an impact, on first time and lower income homebuyers and homebuyers of color than guarantee fees. In our view, the proposed requirements will unnecessarily raise the cost of credit for the very borrowers for whom the GSE mission is most important, and we suggest that significant adjustments be made before finalizing them.