In a strongly worded blog post published Thursday, Bob Broeksmit vigorously defended his support for dropping tri-merge credit requirements in mortgage underwriting in favor of a single-file framework.
The president and CEO of the Mortgage Bankers Association (MBA) has consistently claimed that an optional single-file framework would lower costs for mortgage borrowers and lenders on the conventional side of market supported by government-sponsored enterprises Fannie Mae and Freddie Mac without injecting undue risk.
“The tri-merge credit reporting requirement has become a license for price gouging and ripping off consumers,” Broeksmit wrote. “MBA and its members have had enough.”
The tri-merge model requires lenders to pull credit reports from the three nationwide consumer credit bureaus — TransUnion, Experian and Equifax — for every borrower, which Broeksmit had previously called “an outdated relic of a time when data was fragmented and inconsistent, leading to significant disparities between the reports.”
But not all mortgage trade groups have thrown their support behind the single-file strategy, which would allow lenders to underwrite loans using just one credit report from one of the national credit bureaus if the initial report shows a borrower’s credit score at 700 or above.
Last week, the Community Home Lenders of America (CHLA) published an addendum to a white paper first released in January 2024 detailing recent developments in the credit scoring industry. The addendum enumerates more than a dozen “unresolved issues and concerns” that underscore the CHLA’s rejection of the single-file framework.
“Costs will likely not be reduced — and could increase,” said the CHLA, a headline concern directly conflicting with MBA assertions that a single-file framework would reduce costs.
CHLA is also concerned about increased repurchase risk, higher mortgage insurance rates, data disparities between the credit bureaus, best execution for loan delivery, poor coordination between federal housing regulators and the incentivization of “score fishing.”
“Proponents of the single bureau option say all three credit bureaus produce similar results,” the Jan. 14 addendum reads. “However, the facts don’t support this.”
“MBA and its members have had enough.”
In his Thursday blog post, Broeksmit responded point by point to the CHLA’s objections, excerpting portions of the CHLA’s addendum to respond to directly.
The CHLA has said that a single-bureau credit pull model “could disadvantage veterans, rural families and first-time homebuyers,” particularly those applying for mortgages outside the conventional market. Broeksmit responded that the current tri-merge model “imposes substantial systemic costs driven by low pull-through rates,” which, if reduced with the single-file option, “would lower overall origination costs, benefiting all borrowers.”
Regarding the CHLA’s concern that housing regulators at the Federal Housing Administration, Department of Veterans Affairs and the Federal Housing Finance Agency, which oversees Fannie and Freddie, do not coordinate on credit score reforms, Broeksmit said government agencies “may be able to adjust their policies in the future, tailored to each program’s risk profile.” He reiterated that lenders “can also choose to pull three at the outset for any borrower, as no one is advocating for a requirement that lenders can pull only one report.”
One of the CHLA’s most strident objections to the single-file framework concerns the lack of data consistency in what gets reported to the major credit bureaus, citing credit industry data showing that 23% of consumer data is not reported to all three bureaus. The single-file framework could increase rather than decrease disparities between which sources of consumer data are being used to make decisions across the credit spectrum, CHLA believes.
To this Broeksmit replied that internal and industry reviews of tradeline coverage data shows “the large and significant sources of the most predictive consumer debt are consistent furnishers to all three bureaus.”
Meanwhile, he added, “incentives to innovate or improve are not present in the tri-merge credit reporting market today,” but transitioning to a single-file framework gives Fannie and Freddie “an incentive to exercise greater counterparty oversight over the bureaus.”
In response to a request for comment on Broeksmit’s blog post, CHLA Executive Director Scott Olson stated, “Our CHLA white paper represents detailed internal discussions with our CHLA members and our consensus thoughts on the issue.”
FHFA Director Bill Pulte, for his part, has been critical of the legacy credit reporting system and has taken to social media to call for reform. He stopped short of formally advocating for a move away from the tri-merge model during a July 2025 interview with Scotsman Guide, though he noted that “we always will keep our mind open for whatever is in the best interest of the American consumer.”
The formal push to reform credit scoring began in 2018 when Congress passed the Credit Score Competition Act during President Donald Trump’s first administration, though critics of the credit reporting system have long described the three major credit bureaus as a government-shielded oligopoly suppressing innovation and market competition in pricing.
In December, when asked to respond to a letter Broeksmit sent to Pulte advocating for a single-pull standard, an FHFA spokesperson replied, “We are moving quickly to implement the Credit Score Competition Act of 2018 signed by President Trump and bring much-needed competition to the credit score marketplace.”
