The Mortgage Bankers Association (MBA) published research Friday in support of phasing out tri-merge requirements in mortgage underwriting for applicants boasting credit scores over certain thresholds.
The Federal Housing Finance Agency, regulator of Fannie Mae and Freddie Mac, announced in mid-April that the government-sponsored enterprises would begin accepting home loans underwritten using VantageScore 4.0 on a limited basis, as part of ongoing efforts to increase competition and innovation in the credit scoring industry.
The three national credit bureaus — Experian, Equifax and TransUnion — launched the first iteration of VantageScore in 2006 to compete with the longstanding and dominant Classic FICO model in consumer credit markets.
But the MBA has insisted that the underlying tri-merge requirement, which forces lenders to pull borrower credit scores from all three national bureaus, also represents an outdated and costly regulation driving up expenses for borrowers and lenders.
Testifying before the House Subcommittee on Housing and Insurance in February, Bob Broeksmit, president and CEO of the MBA, said Fannie and Freddie “should eliminate the requirement for a tri-merge on every loan and adopt an alternative credit reporting framework that gives lenders the flexibility to order only one report.”
For borrowers with credit scores above 700, the MBA favors a single-file option with restrictions to protect against score shopping.
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Opponents of the single-file proposal, such as the Community Home Lenders of America, which represents mostly small and midsize mortgage lenders, cite a lack of data consistency between the bureaus and the likelihood of incentivized score shopping and potentially higher repurchase risk and investor risk premiums.
In its analysis released Friday, the MBA said its limited study of loan-level data supports the feasibility of single-file pulls, at least concerning loan-level price adjustments (LLPAs) across Fannie’s and Freddie’s pricing matrixes.
Examining nearly 105,000 mortgage loan applications handled by ICE Mortgage Technology during the first half of 2025, the MBA found that 68% of borrowers would remain in the same LLPA bucket if lenders had used just one score from a randomly selected credit bureau instead of a tri-merged score.
Furthermore, the MBA found that more than 9 in 10 applications would fall in the same bucket, or one tier higher or lower under the single-file scenario, while the shares of loans moving one bucket higher or lower were “roughly comparable.”
Edward Seiler, associate vice president for housing economics at the MBA, said the observed effect “largely holds throughout the entire LLPA grid and implies that the move to a single file would have little impact on credit risk and little impact on LLPA revenue.”




