Freddie Mac introduced a front-end credit risk-transfer pilot program this week, but industry observers say it doesn’t include some of the features that many private mortgage insurers and mortgage bankers have been looking for. Guarantee fees will not be lowered because of the deep MI pilot and lowering them is something that the Mortgage Bankers Association has been advocating. Moreover, it’s not the deep-cover primary insurance that private MIs were hoping to write. The GSE is purchasing additional coverage beyond the primary MI contract from a group of four MI firms on 30-year fixed-rate mortgages with loan-to-value ratios of 80 to 95 percent. The coverage is then placed immediately as loans are sold to the GSE.