FHFA Weighs Shift From Three-Bureau to Two-Bureau Credit Checks

The Federal Housing Finance Agency is weighing a change that would let mortgage lenders pull credit reports from two credit bureaus instead of three, according to a report from National Mortgage Professional. FHFA oversees Fannie Mae and Freddie Mac, the government-sponsored enterprises that buy or guarantee most conventional home loans in the United States, which gives the agency effective control over what documentation lenders must collect before a loan can be sold to either company.

What is FHFA proposing?

The National Mortgage Professional report frames the move as a potential break from the industry's long-standing "tri-merge" credit pull, the practice of checking a borrower's file with all three nationwide credit reporting companies before closing a conventional mortgage. A shift to "bi-merge" would mean lenders check only two of the three files. The report did not specify which bureau might be dropped, when a final rule could take effect, or whether the change would apply to purchase loans, refinances, or both. Those details were not included in the available reporting, and this piece does not speculate beyond what was published.

What is the difference between tri-merge and bi-merge credit reports?

Tri-merge reporting has been the default for conventional mortgage underwriting for decades. A lender orders a combined file pulling data from Equifax, Experian, and TransUnion, then typically uses the middle of the three resulting scores to qualify a borrower. The logic is that no single bureau has a complete record of every account, so blending three files catches discrepancies that a single-bureau check might miss. A bi-merge system would drop one bureau from that process, relying on two files instead of three to determine a borrower's score and qualifying terms.

Why would FHFA want fewer credit bureaus involved?

The National Mortgage Professional report ties the idea to FHFA's broader scrutiny of the credit reporting system that underpins mortgage underwriting, though the specific cost or policy rationale behind a bi-merge requirement was not detailed in the available coverage. Lenders have long paid a fee for each bureau pulled in a tri-merge report, and borrowers' negative perceptions of credit-scoring itself are not new. A separate HTT survey found residents in San Francisco report largely negative views of how credit scores are calculated and used, underscoring why any change to the underlying reporting mechanics draws attention from both lenders and consumer advocates.

A shift from tri-merge to bi-merge would not change what is on a borrower's credit file — it would change how many of those files a lender is required to check before approving a conventional mortgage.

How would this change affect mortgage applicants?

For a borrower, the number of bureaus checked can matter because scores often differ by bureau depending on which creditors report to which agency. Dropping one bureau from the mix could change which score a lender sees and uses to qualify an applicant, potentially altering approval odds or the interest rate offered, though the direction and size of that effect would depend on which bureau is removed and how lenders adjust their underwriting guidelines in response. None of those mechanics were specified in the National Mortgage Professional report, and FHFA has not published a formal rule describing them as of this writing.

What happens next?

FHFA has not released a public rule or guidance document laying out a bi-merge requirement, based on the reporting available. Any formal change to Fannie Mae and Freddie Mac underwriting standards typically goes through agency guidance to lenders before taking effect, giving loan officers, credit bureaus, and consumer groups a window to respond before new rules are enforced. Mortgage applicants with questions about how their own credit file might be affected can request reports directly from Equifax, Experian, and TransUnion to see where their scores currently diverge.

Does this affect borrowers with thin credit files?

The National Mortgage Professional report does not break out how a bi-merge standard would treat borrowers who have a file with only one or two of the three bureaus, a common situation for applicants who are new to credit or who use credit sparingly. Under tri-merge rules, a thin file at one bureau is typically offset by fuller records at the other two, since the lender still pulls all three before selecting a score. Whether a two-bureau standard would preserve that cushion, or narrow it, was not addressed in the available coverage, and FHFA has not published guidance describing how edge cases would be handled.

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