A long-running fight over the industry's three-bureau credit report requirement is coming to a head, with the Federal Housing Finance Agency (FHFA) reportedly preparing to make its next move.
FHFA Director Bill Pulte is said to announce as soon as Oct. 12 that Fannie Mae and Freddie Mac will move toward allowing credit data from two of the three nationwide credit bureaus rather than requiring all three. Pulte is scheduled to appear that day with Mortgage Bankers Association President and CEO Bob Broeksmit at MBA's Annual Convention in Chicago.
FHFA has not publicly announced the change, and its current guidance says the expansion of VantageScore 4.0 has not initially altered the Enterprises' credit-reporting requirements. The agency does say, however, that it continues to assess additional changes aimed at lowering consumer costs and promoting competition while maintaining safety and soundness.
Now, the credit-reporting industry is making its case for keeping all three bureaus in the mortgage process.
The Consumer Data Industry Association, which represents consumer reporting agencies including the three nationwide credit bureaus, said reducing the amount of credit data used in mortgage underwriting could introduce additional costs and risks.
"More data, not less, produces better outcomes, and keeps borrowing costs down," CDIA President and CEO Dan Smith said. "Lenders and borrowers benefit from the most complete, accurate picture, which is why maintaining the tri-merge credit report is critical to the safety and soundness of the mortgage industry."
The argument puts CDIA directly at odds with mortgage trade groups that have spent months pushing FHFA to reduce — or in some cases eliminate — the tri-merge requirement.
The outcome could determine more than what a credit report costs. It could change which borrower data reaches underwriting in the first place.
Why Three Reports Can Produce Different Pictures
Under the current tri-merge system, lenders generally receive credit information from Equifax, Experian, and TransUnion.
CDIA argues that the three files aren't necessarily identical because creditors voluntarily furnish information to the credit bureaus and may not report the same information to each one. Combining all three therefore gives lenders a more complete picture of a borrower's credit history, according to the association.
The group points to research from the American Enterprise Institute Housing Center finding an average 26-point difference among bureau scores for borrowers with scores above 700, which it says reflects differences in the information held by each bureau.
CDIA also cites a TransUnion analysis estimating that roughly 300,000 borrowers could receive a different eligibility result under a single-bureau approach compared with tri-merge.
Mortgage Bankers See The Cost Differently
MBA has reached nearly the opposite conclusion.
The association said in September that it supports ending the tri-merge requirement and moving to a single-file approach for borrowers with strong credit profiles, arguing that additional competition would lower costs for consumers.
In a December 2025 letter to Pulte, MBA said its members were facing average credit-reporting cost increases of 40% to 50% for 2026 after several consecutive years of increases. MBA argued that requiring lenders to obtain reports from all three bureaus effectively eliminates competition among them for mortgage business.
Broeksmit sharpened that argument earlier this year, saying MBA believes single-file lending could be done with appropriate guardrails and business rules. MBA also asked FHFA, Fannie Mae, and Freddie Mac to refresh and publicly release their analysis comparing single-, bi-, and tri-merge approaches.
CDIA counters that the cost of the underlying tri-merge report needs perspective. Its new analysis estimates an $80 to $100 tri-merge report represents less than 1% of approximately $12,500 in typical mortgage closing costs.
That leaves the two sides arguing over a fundamental tradeoff: whether requiring three bureau files provides enough additional underwriting information to justify the expense, or whether lenders and borrowers are paying for data that could safely be reduced.
Bi-Merge Isn't A New Idea
Despite the renewed fight, moving away from mandatory tri-merge reporting isn't a new direction for FHFA.
The agency first announced in 2022 that Fannie and Freddie would permit lenders to use either tri-merge or bi-merge reporting. In 2024, FHFA planned to implement bi-merge alongside its broader transition to new credit-score models, saying the change was expected to promote greater competition.
That transition never happened on the original schedule.
In January 2025, FHFA and the Enterprises moved the implementation date for the new scoring requirements and optional bi-merge reporting from the fourth quarter of 2025 to a date to be determined following industry feedback.
The current debate therefore isn't whether FHFA has ever considered two-bureau reporting. It is whether Pulte is now ready to put that long-delayed change into practice — and what form it will take.
Last month, Pulte said he was "seriously considering" bi-merge while also studying whether mortgages could ultimately be evaluated using information from only one bureau. At the time, FHFA had just opened VantageScore 4.0 to all approved GSE lenders.
More recent reporting points specifically toward bi-merge as FHFA's next step, although the agency has yet to formally announce the policy.
The Fight Isn't Just Over Cost
Another point of contention is who would determine which bureau files are used.
CDIA warns that reducing the number of reports could create opportunities for what it calls "credit score shopping," with lenders selecting files that produce more favorable outcomes rather than relying on the complete three-bureau picture.
MBA, meanwhile, has argued that appropriate business rules could address concerns about incomplete information or gaming and has called for updated GSE analysis to determine how material the differences actually are.
The details of any FHFA policy will therefore matter considerably, including whether lenders can choose which two bureaus to use, whether that selection is standardized, and what safeguards apply.
For LOs, Credit Is Becoming A Bigger Decision Tree
The potential change arrives while LOs are already adjusting to a market in which the credit score itself is becoming a choice.
FHFA opened VantageScore 4.0 to all approved Fannie Mae and Freddie Mac lenders in September. Since then, some of the industry's largest lenders have begun showing how different scoring models can produce different outcomes on actual loans.
Rocket Mortgage said it will make VantageScore 4.0 its preferred scoring model for eligible retail loans during the fourth quarter after testing it alongside Classic FICO, while Rocket Pro continues to make both models available to brokers. Rocket said more borrowers met credit requirements using VantageScore during its testing.
United Wholesale Mortgage has similarly given brokers both scoring options. Last week, UWM eliminated the 20-point adjustment it had previously applied to VantageScore, just as Fannie and Freddie aligned pricing across VantageScore 4.0 and Classic FICO.
Changing the number of bureau files would introduce another variable.
An originator could eventually be dealing not only with which scoring model produces the better result for a borrower, but which credit-reporting framework applies to the loan.
The Federal Housing Administration has already chosen a different path. FHA said in May that it would continue requiring tri-merge reports even as it expands the credit-scoring models available for FHA loans, saying the three-bureau requirement supports comprehensive and consistent credit evaluation and prudent risk management.
If Fannie and Freddie begin allowing bi-merge while FHA maintains its tri-merge requirement, LOs could face different credit-reporting frameworks depending on the loan program and lender — at the same time lenders are developing their own strategies around Classic FICO and VantageScore 4.0.
For an LO comparing executions, that could eventually mean navigating not only different loan programs and scoring models, but different combinations of bureau data feeding those decisions.
