MBA Advocacy Update: Trigger Leads Bill Passes; End of Tri-Merge Mandate; GSEs Expand Housing Finance

MBA President and CEO Bob Broeksmit, CMB, discusses credit score modernization and news that MBA’s Residential Board of Governors passed a resolution calling for the end of the mandatory tri-merge credit report requirement to originate GSE loans. Watch it here.

Trigger Leads Bill Nears Enactment

Late Saturday evening, just before the Senate gaveled out for the August recess, the Homebuyers Privacy Protection Act of 2025 (H.R. 2808) passed the Senate by unanimous consent. The final passage of the legislation by both the House and the Senate, by voice vote and by unanimous consent respectively, is a significant MBA advocacy win. 

• Senate adoption of the House-passed bill means the legislation goes to the President’s desk for signature, and once signed, this brings to conclusion a multi-year effort to curb the abusive use of mortgage trigger leads while preserving their use in appropriately narrow circumstances.

What they’re saying: In a press statement, MBA President and CEO Bob Broeksmit, CMB, said, “MBA celebrates the final passage of this important bill — a long-overdue measure that will finally put an end to the abusive use of mortgage credit trigger leads. This new law will help protect consumers from the barrage of unwanted calls, texts, and emails they too often receive immediately after applying for a mortgage. It marks a major victory for borrowers and will create a more efficient, responsible, and respectful home buying process. MBA and its members thank trigger lead reform champions Senators Bill Hagerty (R-TN) and Jack Reed (D-RI), and Reps. John Rose (R-TN) and Ritchie Torres (D-NY), for their leadership throughout this legislative process, as well as the large bipartisan group of lawmakers in both chambers who helped shepherd a uniform bill across the finish line. We look forward to President Donald Trump signing this bill into law and will work to ensure a seamless transition when it goes into effect in six months.”

Why it matters: Six months after enactment, trigger leads will be permissible under the Fair Credit Reporting Act only in limited circumstances during a real estate transaction and only to provide a firm offer of credit. The full text of the bill as passed can be found here.

Go deeper: This proposal would never have emerged if not for the inspirational leadership of past RESBOG Chair, the late Chrissi Rhea, who led MBA’s internal policy discussions to make ending abusive trigger leads a top MBA priority. Over the course of the 118th and 119th Congresses, MBA assiduously worked to advance the legislation in the House and in the Senate.

• The House bill (H.R. 2808) had 89 bipartisan House cosponsors, and the Senate bill (S. 1467) had 45 bipartisan Senate cosponsors. The Senate bill passed the bill twice over a two-year period and the House once, with the addition of a study and report to Congress on text messages. The legislation that will be enacted into law upon the President’s signature passed with all of the original bill’s key operational elements intact. The House Financial Services Committee added a Government Accountability Office (GAO) study on the whether trigger leads received by text message are useful.

What’s next: MBA looks forward to President Trump signing the bill into law quickly and will work to ensure a seamless implementation when it goes into effect in six months.

For more information, please contact George Rogers at (202) 557-2797, Ethan Saxon at (202) 557-2913, Rachel Kelly (202) 557-2816 and/or Madisyn Rhone at (202) 557-2741.

MBA Calls for the End to the Tri-Merge Mandate

On Tuesday, MBA’s Residential Board of Governors (RESBOG) passed a resolution urging the Federal Housing Finance Agency (FHFA) to end the requirement for a tri-merge credit report for every loan purchased by Fannie Mae and Freddie Mac (the GSEs) and to adopt an alternative credit reporting framework that incents competition among the bureaus to improve accuracy and lower costs. 

Why it matters: MBA has been exploring the feasibility of a single credit report for both the GSEs and government-guaranteed loans in response to ongoing concerns with the rising costs of credit scores and credit reports, as well as the market-distorting impacts of a government-mandated purchase from each of the three providers. The current tri-merge mandate inhibits competition among the credit bureaus and stifles innovation in credit reporting practices. 

• RESBOG voted to support modernizing the mortgage credit reporting framework, like the existing practices in almost all other forms of lending that require credit reports and scores, to lower consumer costs and improve service quality.

Go deeper: As MBA’s President and CEO, Bob Broeksmit, CMB, noted in a recent blog post following FHFA’s recent directive to the GSEs to permit the use of Vantage Score, MBA applauds efforts to modernize credit scores. MBA will collaborate with FHFA and the GSEs to support the Administration’s credit score transition, but at the same time MBA urges FHFA and the GSEs to go further and foster competition in the credit reporting market by eliminating the GSE requirement for a tri-merge credit report on every loan. 

What’s next: MBA will continue to assess different credit reporting alternatives, including a single or bi-merged credit report, and consider the necessary business rules to balance risk concerns with the need to reduce costs to consumers. For instance, leveraging other data sources, such as consumer permissioned banking and asset data, could provide a less costly way to fill any information gaps, rather than purchasing two additional credit reports.

• Given the confidentiality requirements imposed by many sellers of credit reports, which make a public evaluation of borrower performance difficult, MBA continues to urge FHFA and the GSE to publicly release their analyses on the potential impacts of transitioning to a bi-merge or single report structure.

For more information, please contact Brendan Kelleher at 202-557-2779 or Sasha Hewlett at 202-557-2805.

Freddie Mac Expands Financing for Manufactured Housing

On Wednesday, Freddie Mac announced it is expanding its CHOICEHome conventional financing program to include modern single-section factory-built homes. Under the updated program, lenders can now offer CHOICEHome mortgages for single-section homes, appraised using similar methods as site-built properties. Freddie Mac currently offers CHOICEHome financing for multi-section factory-built homes with as little as 3% down, and the same option will now apply to single-section homes.

Why it matters: Single-section factory-built homes cost significantly less than traditional site-built homes.

What’s next: MBA supports Freddie Mac’s expansion of its housing finance options to enhance affordable housing supply and help first-time and lower-income buyers enter the market. MBA will continue to monitor updates from the GSEs through the MBA Residential Loan Production Subcommittee and Construction Lending Working Group.

For more information, please contact Darnell Peterson at (202) 557-2922 or John McMullen at (202) 557-2796.

REMINDER: Help MBA Identify Ways to Reduce Regulatory Burden Across the Banking Industry

On July 21, the Federal Banking Agencies announced they are seeking input from industry on ways to reduce regulatory burden. Very rarely is the industry offered the opportunity to comment broadly on the entire bank regulatory framework.

• MBA plans to take full advantage of this unique opportunity to help regulators understand areas where changes to current mortgage-related supervisory standards and guidance would lower costs for banks and increase their support for the mortgage market through direct lending, servicing and warehouse banking of IMBs.

• Final comments are due to the Agencies by October 23rd.

Why it matters: Regulatory issues like misaligned capital standards, overly burdensome Community Reinvestment Act requirements, or excessively narrow supervisory oversight of consumer lending compliance can have a large impact on day-to-day business operations.

What’s next: MBA will compile feedback from our members to guide our comment letter.

For more information, please contact Fran Mordi at (202) 557-2860.

MBA Engages with Key Policy Makers at National Council of State Legislatures Annual Conference

Last week, MBA attended the National Conference of State Legislatures’ Policy Summit in Boston, Mass. The summit focuses on pressing issues state legislators are currently addressing and offers a forum for industry groups to discuss potential solutions while gaining insight into legislative priorities for 2026.

Go deeper: Several sessions centered on critical topics including rent control measures, the availability and cost of homeowners insurance, ongoing housing shortages, and the evolving interest in regulating artificial intelligence (AI).

• Sessions on homeowners’ insurance highlighted how legislators are working to balance affordability and access with market realities.

• While in other sessions, the messaging was mixed for the approach to rent control and AI, how consumer or tenant protection may mean greater risk to investment or innovation.

Why it matters: During conversations with attendees, MBA shared national perspectives and ongoing work related to these areas and fostered engagement by legislators with MBA’s partner associations in their respective states. Additionally, MBA highlighted its perspectives on AI policy to help clarify the implications of overreaching rules on the housing finance market, especially regarding key mortgage technology. The summit provides valuable insights into how these issues are being addressed across states, shaping future legislative approaches and positioning MBA as a resource for policymakers.

What is next: MBA will provide a detailed recap of this event at the next State Legislative & Regulatory Committee call August 21st, 2:00-3:00pm ET. To ensure an invite for this call, please email lfacemire@mba.org.

For more information, please contact William Kooper at (202) 557-2737 or Liz Facemire at (202) 557-2870.

MBA Urges Financial Reporting Alignment at AARMR Conference; NMLS Changes Coming in September

During the NMLS Ombudsman meeting at the annual American Association of Residential Mortgage Regulators (AARMR) conference last week, MBA staff and MBA State Legislative and Regulatory Committee Chair, Joshua Weinberg, CMCP (President, Firstline Compliance, LLC.) urged state mortgage regulators to join industry in establishing a new MISMO working group tasked with fully aligning the data sets of the NMLS Mortgage Call Report (MCR) and the Mortgage Bankers Financial Reporting Form (MBFRF). 

Both regulators and their staff expressed support for the concept and cited the successful MISMO work on the Mortgage Compliance Data Set, which has driven consistency and reduced burden for all stakeholders.

Why it matters: Creating greater symmetry between these quarterly reporting requirements has great potential to reduce costs and significantly streamline operations for MBA members.

Go deeper: The Conference also included a keynote from MBA’s Marina Walsh, CMB, as well as a discussion of multiple changes coming this fall to the NMLS. These include:

• improvements to the individual application process; 

• enhanced functionality of the NMLS Resource Center to improve navigation and provide more streamlined content for companies and individuals; and

• system updates to accommodate new policies for disclosure questions, remote work, unsubmitted filings, and MCR Form Version7.

Starting September 20, 2025, all old URLs and bookmarks will be redirected to the new NMLS homepage. Also, while core NMLS materials will remain, they may appear in new locations or formats and outdated or unnecessary content will be retired. NMLS hopes that these improvements will make the system more user-friendly and modern.

• In this regard, MBA recommends members prepare for these changes by reviewing the information at www.csbs.org/nmls-modernizationState Regulated Industry Town Hall #1 Recording, and the Town Hall FAQs.

What’s next: MBA will continue to pursue its MISMO suggestion with state regulators and work to ensure members are prepared for NMLS’s modernization efforts ahead of licensing renewal season.

For more information, please contact William Kooper at (202) 557-2737 or Liz Facemire at (202) 557-2870.

Senate Passes MBA-Supported Trigger Leads Bill; Heads to President Trump’s Desk for Enactment

On Saturday evening, the full U.S. Senate passed the Homebuyers Privacy Protection Act of 2025 (H.R. 2808) by unanimous consent.  

• The final passage of this bill is a significant MBA advocacy win, one that brings to conclusion a multi-year effort to curb the abusive use of mortgage credit leads while preserving their value in appropriately limited circumstances.

• MBA thanks the thousands of Mortgage Action Alliance (MAA) members who participated in calls to action this year during the 119th Congress – and the prior Congress as well. YOUR VOICE mattered as MBA led a diverse coalition that pushed leaders in the House and Senate to ultimately reach a consensus after the proposal was tweaked at various points in the legislative process – and then harmonized and passed by both chambers.

• A big “shout-out” is also due to our trigger leads reform champions – Senators Bill Hagerty (R-TN) and Jack Reed (D-RI) and Reps. John Rose (R-TN) and Ritchie Torres (D-NY) – for their tireless efforts to steer this MBA-supported proposal across the finish line.

What they’re saying: In a press statement, MBA President and CEO Bob Broeksmit, CMB, said, “MBA celebrates the final passage of this important bill — a long-overdue measure that will finally put an end to the abusive use of mortgage credit trigger leads.

“This new law will help protect consumers from the barrage of unwanted calls, texts, and emails they too often receive immediately after applying for a mortgage. It marks a major victory for borrowers and will create a more efficient, responsible, and respectful home buying process.”

Why it matters: Following six months after enactment when President Donald Trump signs the legislation into law, trigger leads will be permissible under the Fair Credit Re porting Act only in limited circumstances during a real estate transaction and only to provide a firm offer of credit.

• A credit reporting agency (“CRA”) would not be able to furnish a trigger lead to a third party unless the third party has certified to the CRA that either:

• The consumer explicitly consents to such solicitations;

• The third party has originated the current residential mortgage loan of the consumer;

• The third party is the servicer of the current residential mortgage loan of the consumer; or

The third party is an insured depository institution or insured credit union and holds a current account for the consumer.

Go deeper: This proposal would never have emerged if not for the inspirational leadership of past RESBOG Chair, the late Chrissi Rhea, who led MBA’s internal policy discussions to make trigger leads reform a top association priority, helping it go from being a draft concept to public law in a matter of just a few years. To all of Chrissi’s past colleagues and friends, we couldn’t have done this without her!

What’s next: MBA looks forward to President Trump signing the bill into law quickly and will work to ensure a seamless implementation when it goes into effect in six months.

For more information, please contact George Rogers at (202) 557-2797, Ethan Saxon at (202) 557-2913, Rachel Kelley at (202) 557-2816 and/or Madisyn Rhone at (202) 557-2741.

Last week, MBA President and CEO Bob Broeksmit, CMB, penned two blog posts on two major advocacy initiatives (and wins): MBA’s work with FHFA and the GSEs on credit score modernization, and President Trump signing the VA Home Loan Program Reform Act into law. Read them here and here.

Upcoming MBA Education Webinars on Critical Industry Issues

MBA Education continues to deliver timely single-family programming that covers the spectrum of challenges, obstacles and solutions pertaining to our industry. Below, please see a list of upcoming and recent webinars – all complimentary to MBA members:

Non-Agency Training Series: DSCR Loans – Aug. 12
Freddie Mac Income Calculator: Deriving Precise Income with Speed – Aug. 13
How Executives Use Social Media to Influence, Inspire, and Lead with Purpose – Aug. 19
Closing With Confidence Series – Part I – August 21
Non-Agency Training Series: Bank Statement Loans – Aug. 26
Reverse Mortgages: State of Play – Aug. 27
Benchmarking for Performance and the Performance Ratios Every Mortgage Banker Must Know – Sept. 3.

MBA members can register for any of the above events and view recent webinar recordings by clicking here.

For more information, please contact David Upbin at (202) 557-2931.