Advocacy Update: Bob Broeksmit on Ending Tri-Merge Mandate for GSE Loans; FHFA-HUD Announcement on VantageScore 4.0 and FICO 10T; MBA’s Housing Affordability Checklist for Housing Agencies

FHFA, HUD Announce Next Steps for VantageScore 4.0, FICO 10T Adoption

On Wednesday, Federal Housing Finance Agency (FHFA) Director William Pulte and Department of Housing and Urban Development (HUD) Secretary Scott Turner, in joint press conference, outlined next steps for the adoption of VantageScore 4.0 and FICO 10T.  

Fannie Mae and Freddie Mac (the GSEs) have updated their selling policies to allow for the current use of VantageScore 4.0 and the future use of FICO 10T. The GSEs will begin accepting mortgages assessed using VantageScore 4.0 through a limited rollout to 21 approved lenders. Program parameters, pricing, and business rules on score choice remain confidential at this time.    

• Director Pulte emphasized that rather than a “pilot program,” the rollout will allow approved lenders to ensure the new models and systems are operationally ready.

• FHFA also announced it will publish the long-awaited FICO 10T historical credit score data “this summer” for loans acquired between April 2013 and September 2025, as well as additional data for VantageScore 4.0 between April 2023 and September 2025.

• Secretary Turner said that the Federal Housing Administration (FHA) “in the next few months” will permit the use of VantageScore 4.0 and FICO 10T as eligible credit scoring models for FHA-insured mortgage underwriting.

• Notably, in response to a reporter’s question, Director Pulte lauded efforts to bring competition to the credit scoring space and said, “I think the credit bureaus are probably next in terms of attention.” (See: 22:24 of video)

What they’re saying: In a press statement, MBA’s Broeksmit said, “MBA has long advocated for greater competition in the credit reporting and scoring space. Today’s announcement marks an important next step in modernizing the credit scoring framework used by Fannie Mae and Freddie Mac and FHA.”

Broeksmit added, “MBA will also continue to press for reforms of the tri-merge credit reporting requirement, including implementing a single-report requirement for GSE borrowers with strong credit profiles, to encourage greater competition and lower costs for consumers.”

Why it matters: MBA has consistently advocated for increased competition in credit reporting and scoring and welcomes reforms that will lower costs for consumers. FHFA’s and HUD’s announcement to allow lenders to use VantageScore 4.0 and FICO 10T would help accomplish the goals of added competition in the credit score space, increased credit availability, and reduced consumer costs.

What’s next: MBA will work with FHFA, the GSEs, and HUD to get VantageScore 4.0 (and FICO 10T) available as soon as possible to all lenders to ensure that the benefits of competition and modern scores are available to all lenders and their customers. MBA will also continue to press for reforms of the tri-merge credit reporting requirement to encourage greater competition and lower costs for consumers.

For more information, please contact Sasha Hewlett at (202) 557-2805.

MBA Publishes Housing Affordability Checklist for the Federal Agencies

MBA recently published its Housing Affordability Checklist for the federal government agencies.

• The Checklist outlines MBA policy priorities aimed at increasing affordability, lowering borrower costs, safely expanding credit availability, reducing mortgage production and servicing expenses, and modernizing the housing finance system.

Go deeper: MBA extends its sincere appreciation to the members of the Affordable Homeownership Advisory Council, the Residential Loan Production Committee, and MBA’s Residential Board of Governors for their contributions to the checklist.

Why it matters: All items on the checklist can be addressed through administrative actions by the federal agencies, without requiring legislation from Congress. Among the key items highlighted in the checklist are:

• Ending the tri-merge mandate and adopting a single-file credit report framework for scores above 700;

• Reducing Loan Level Price Adjustments (LLPAs) for purchase loans and aligning LLPAs for rate/term refinances with those for purchases;

• Modernizing the Consumer Financial Protection Bureau’s (CFPB) Reg X to provide streamlined loss mitigation to borrowers in default; and,

• Publishing calibrated bank capital rules according to actual risk of mortgage assets (through the eventual Basel III Endgame final rule).

What’s next: MBA intends to update the Checklist periodically as policy developments emerge, and new opportunities to improve housing affordability, are identified. Members can find the most up-to-date version of the Checklist here. Supporting materials on these issues, including comment letters, white papers, and issue briefs, can all be accessed on the All Letters and Testimony and Residential Policy Issues pages at MBA.org.

For more information, please contact Anthony Siller at 202-557-2944.

CFPB Issues Final Rule Amending Regulation B

On Wednesday, the CFPB (or Bureau) issued a Final Rule amending Regulation B – which implements the Equal Credit Opportunity Act (ECOA).

• The CFPB largely finalized the rule as proposed, with only clarifying edits rather than substantive revisions. Notably, the CFPB did so after receiving approximately 65,000 comments on the proposal from industry, consumer advocates, state attorneys general, and members of Congress. The rule will become effective on July 21, 2026.

• MBA’s summary of the Final Rule is available here.

• While this is a significant rulemaking with respect to federal anti-discrimination laws generally, it is important to note that much of the conduct covered by ECOA with respect to mortgage lending is already covered by the Fair Housing Act, including disparate impact claims.

Go deeper: MBA broadly supported the Bureau’s changes in a letter and asked for additional clarifying guidance where appropriate. The Final Rule:

• Limits discrimination claims under ECOA only to acts where creditors treat borrowers differently based on their protected characteristics.

• Limits discouragement claims to written statements or visual presentations, not acts or practices, such as the placement of branch offices, or marketing aimed at one group over another.

• Lastly, Special Purpose Credit Programs (SPCPs) created by for-profit institutions can no longer use race, color, national origin, or sex as eligibility criteria for the program.

What’s next: MBA will keep members informed about any further developments.

For more information, please contact please contact Justin Wiseman at (202) 557-2854 or Alisha Sears at (202) 557-2390.

MBA Responds to CFPB Draft Strategic Plan for FY 2026-2030

MBA recently sent a letter to the CFPB in response to its Strategic Plan for FY 2026-2030. At a high level, the Strategic Plan includes three goals. The CFPB will:

• Concentrate its resources on identifying and addressing pressing threats to consumers.

• Reduce regulatory overreach by streamlining existing regulations and reducing unjustified burdens.

• Work on improving the performance and management of the Bureau internally.

    Go deeper:  MBA’s letter supports the aim of the Strategic Plan to concentrate the CFPB’s resources on identifying and addressing pressing threats to consumers, reversing instances of regulatory overreach, and lowering the compliance and liability costs associated with consumer financial products.

    • MBA expressed appreciation for recent CFPB actions that are consistent with the goals of the strategic plan, including rescinding the rule requiring certain types of nonbank covered persons subject to certain final public orders to report the existence of the orders and related information to a CFPB registry and stopping regulation by enforcement.

    As a next step, MBA recommends that the CFPB incorporate the objectives of President Trump’s recent executive order on mortgage credit into the CFPB’s strategic plan and add the following recommendations into the plan. MBA urged CFPB to prioritize:

    • Completing the pending Regulation X to remove unnecessary barriers that impede a servicer’s ability to offer streamlined loss mitigation to borrowers facing financial hardship while dropping the language access proposals;

    • Exercising the Bureau’s exemption authority to revise the Loan Originator Compensation Rule under Regulation Z according to MBA’s priorities;

    • Modifying verification standards for QM/ATR requirements and simplify disclosures under TILA to facilitate streamlined refinances for conventional (non FHA/VA) loans; and,

    • Review allowable TRID tolerances in instances where lenders do not have control over the service providers or retain the charge disclosed.

    What’s next: MBA will keep members informed about any updates to the Strategic Plan and upcoming CFPB rulemakings.

    For more information, please contact Justin Wiseman at (202) 557-2854 or Alisha Sears at (202) 557-2390.

    Federal Reserve Chairman Nominee Warsh Testifies Before Senate Banking Committee 

    Last Tuesday, the Senate Banking Committee held a hearing on the nomination of The Honorable Kevin Warsh be both a Member and Chairman of the Board of Governors of the Federal Reserve System. Republicans on the committee were supportive of Warsh’s nomination and focused on Warsh’s views on price stability, reducing the Fed’s balance sheet, and returning Fed operations to those contained within its core mandates. Democratic committee members were critical of Warsh, questioning the Fed’s independence from the President, raising ethics concerns, and probing Warsh’s views on interest rates, the employment mandate of the Fed, and inflation. 

    • A summary of the hearing can be found here, and the full hearing can be watched here.

    Go deeper: Several Republican Senators asked Warsh about his stance on reducing the Fed’s balance sheet. Warsh said an expanded balance sheet distorts markets, favors financial assets, and weakens the Fed’s credibility. Rather, he supported gradually reducing the balance sheet and returning to interest rate shifts as the primary policy tool to better serve the dual mandate of price stability and maximum employment. Warsh stated that he has no fixed target for the balance sheet and emphasized that any reduction would require public, rigorous deliberation over time. Warsh also said that any increases in the Fed’s balance sheet should be limited to crises.

    • Senator Catherine Cortez Masto (D-NV) criticized Warsh’s previous Fed service both prior to and during the Great Financial Crisis (GFC), stating he was not concerned enough then about subprime mortgages, flipping loans, or the risks of reverse mortgages. Warsh responded that he had for many years before the GFC warned about the potential for Fannie Mae and Freddie Mac “blowing up” and that his urging of GSE reform at the time was not acted upon by those in power. He also argued that subprime mortgages were indicative of a broader mispricing of assets.

    What’s next: On Friday morning, U.S. Attorney General Jeanine Pirro of the District of Columbia said that her office will close its criminal investigation into Federal Reserve Chair Jerome Powell, a move that likely clears a path for Warsh’s nomination to be favorably reported to the Senate floor by the Banking Committee and subsequently confirmed by the full Senate in the coming weeks.

    • Senator Thom Tillis (R-NC), who is supportive of Warsh’s nomination, had previously stated he would block the reporting of any Federal Reserve chairman nomination by the Banking Committee until current legal proceedings against current Fed Chair Jerome Powell regarding statements tied to an ongoing Fed headquarters’ renovation are resolved.

    For more information, please contact George Rogers at (202) 557-2797 or Jeremy Green at (202) 557-2849.

    MBA’s Annual Convention Open for Registration

    MBA has launched the website for this year’s Annual Convention and Expo taking place in Chicago, October 11-14. With the theme “Come Together,” #MBAAnnual26 is the mortgage industry’s largest annual gathering and celebrates the spirit of progress, innovation and the American Dream as the U.S. celebrates its 250th Anniversary.

    Why it matters: The #MBAAnnual26 website will be continuously updated as details on speakers and sessions are confirmed. The best registration prices are available now until June 1.

    What’s next: Currently, Olympians Mike Eruzione and Megan Keller and Emmy Award-winning journalist Norah O’Donnell have been announced.

    For more information and/or to register, visit mba.org/annual.

    MBA, AARMR Launch AI Survey

    MBA, in partnership with the American Association of Residential Mortgage Regulators (AARMR), has launched a new survey to better understand how independent mortgage banks (IMBs) are using artificial intelligence (AI). The survey is being conducted by Boston Consulting Group (BCG).

    Why it matters: State regulators want clear, data-driven insight into AI adoption across mortgage lending. An MBA member focus group worked closely with AARMR to significantly improve an earlier regulator-initiated version. Through this process, MBA ensured that the final survey is both meaningful and protective of member data. Neither MBA nor AARMR will have access to company-specific information – all responses will be kept strictly anonymous within BCG and reported only in aggregate form.

    What’s next: MBA encourages all IMBs to participate to help ensure policymakers and regulators have an accurate understanding of how AI is being used (and not used) in today’s mortgage market.

    For more information, or to request a link for the survey, please contact William Kooper (202) 557-2737 or Rick Hill (202) 557-2718

    Key House Panel Holds Hearing on Reinsurance and CRT

    MBA’s Wednesday, the House Financial Services Committee’s Subcommittee on Housing and Insurance held a hearing to examine how reinsurance and credit risk transfers (CRT) distribute concentrated risk across broader markets, protecting taxpayers and supporting financial system stability. 

    • Ahead of the hearing, MBA joined a coalition letter that urged for support for consistent, programmatic CRTs at Fannie Mae and Freddie Mac with meaningful risk transfer away from the GSEs, preservation of CRT’s countercyclical role across market cycles, and direction to bank regulators to recognize insurance-based CRT so insurers can provide credit protection to banks on a level playing field with global peers.

    • Members focused on whether current GSE CRT structures are effectively transferring meaningful credit risk away from taxpayers and into private markets—or whether recent policy changes have left more risk on GSE balance sheets.

    • A summary of the hearing could be found here.

    Why it matters: The hearing underscored the growing intersection of mortgage finance, insurance availability, and climate risk—an issue increasingly affecting borrower eligibility, loan performance, and housing affordability in high‑risk markets. Lawmakers and witnesses highlighted how CRT pricing can serve as an early warning signal for housing market stress and how reinsurance capacity supports both mortgage insurers and public programs like the National Flood Insurance Program.

    What’s next: The hearing signals potential future legislative and regulatory debates around GSE release, capital rules, and risk-sharing frameworks that will directly affect loan pricing, product innovation, and the resilience of the housing finance system. MBA will continue to work with and inform members of any changes. 

    For more information, please contact Rachel Kelley at (202) 557-2816 or Madisyn Rhone at (202) 557-2741.

    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:

    Closing the Performance Gap: What Top-Tier Mortgage Lenders Do Differently – May 13

    State of the Market: Tech Trends Shaping the Future of Mortgage Lending – May 14

    FHA Credit Watch Program: Revisiting Delinquency Trends and Remediation – May 14

    Structuring the SAR Narrative: A Four-Part Framework That Works – May 19

    Unlocking Opportunity: Innovative Solutions for Affordable Housing in Overlooked Markets – June 9

    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.