Your Mortgage Is Underwritten Off Three Credit Files. The Regulator Is Reportedly Moving to Two.

Two separate things determine the credit assessment behind a conventional mortgage: the data the lender pulls, and the model that turns that data into a number. Both are changing. One change has already happened; the other has been signalled but not formally made.

What a tri-merge report is

There are three nationwide consumer reporting agencies — Equifax, Experian and TransUnion. They are separate businesses and their files are not identical. A lender that furnishes data to one may not furnish to all three; a collection account, a dispute or a corrected error can appear on one file and not the others.

Conventional mortgage underwriting has long used a tri-merge report: all three files, pulled and combined. Pulling all three is more expensive than pulling fewer, and the cost is passed to the borrower in closing costs.

The model change that has already happened

On April 22, 2026, FHFA announced that Fannie Mae and Freddie Mac would accept VantageScore 4.0, and that the Federal Housing Administration would permit both VantageScore 4.0 and FICO Score 10T for underwriting. The agency described it as the first update to the credit scoring models used in mortgage lending in decades. Fannie and Freddie began accepting Vantage-scored loans from approved lenders immediately.

We are modernizing credit scoring with more predictive models, helping millions of Americans who responsibly pay rent qualify for mortgages.

Scott Turner, Secretary of Housing and Urban Development, said in the same announcement that "by embracing additional predictive credit scoring models, we are taking a meaningful step toward expanding access to homeownership." FHFA regulates Fannie Mae, Freddie Mac and 11 Federal Home Loan Banks, which together provide more than $8.5 trillion in funding to US mortgage markets.

A second step followed on pricing. Loan-level price adjustments — the fees Fannie and Freddie charge based on a loan's risk characteristics, including credit score — are set out in grids. FHFA has established a unified grid treating VantageScore 4.0 as equivalent to Classic FICO. Earlier grids had assumed VantageScore overstated creditworthiness by roughly 20 points and priced accordingly. Removing that adjustment means a borrower is not charged more simply because their lender used one approved model rather than the other.

The data change that has been signalled

Separately, Pulte has said publicly that FHFA is weighing a bi-merge requirement, under which a lender would pull two of the three bureaus rather than all three. "Equifax, Experian, and TransUnion have been overcharging Americans for far too long," he wrote on social media. "This will end soon. We are seriously considering bi-merge."

Housing trade press reports the change was expected to be announced at the Mortgage Bankers Association's conference in Chicago on October 12, 2026, with a requirement taking effect one to three months after a formal announcement. The Mortgage Bankers Association has previously argued for allowing single-bureau pulls. FHFA has published no rule, news release or lender letter setting this out, and nothing is in force.

What dropping a bureau would and would not do

The direct effect is on cost: two reports cost less than three, and credit report fees are part of what a borrower pays at closing. The indirect effect runs through the data. Underwriting conventions that use three files have rules for reconciling them — which score governs when they disagree, how to treat a trade line that appears on only one. With two files, there is less information to reconcile and fewer places for a discrepancy to surface.

Which direction that cuts for any individual borrower depends entirely on what is in the files that are pulled and the file that is not. A borrower whose only derogatory item sits on the omitted bureau benefits; a borrower whose only thin-but-positive history sits there does not. The aggregate effect is an empirical question about the distribution of discrepancies across files, and it is not answered by either of the announcements above.