Advocacy Update: GSEs Release Historical Data for VantageScore 4.0, FICO 10T Adoption; more

GSEs Release Historical Credit Score Data for VantageScore 4.0, FICO 10T Adoption

On Wednesday, Fannie Mae and Freddie Mac (the GSEs) each published the long-awaited FICO 10T historical credit score data for loans acquired between April 2013 and September 2025, as well as additional data for VantageScore 4.0 between April 2023 and September 2025.

• The data release, for which MBA has long advocated, will help lenders, investors, and technology providers prepare for a successful transition to a fully modernized credit scoring framework using VantageScore 4.0 and/or FICO 10T.

What they’re saying: MBA President and CEO Bob Broeksmit, CMB, in a press statement said, “We encourage continued collaboration to complete the remaining reviews needed to make both VantageScore 4.0 and FICO 10T broadly available. Doing so will give lenders greater flexibility while providing borrowers with the benefits of using either of the two validated, more predictive credit scoring models, which should score more consumers accurately and expand sustainable access to homeownership. MBA will continue working with FHFA, the GSEs, and industry stakeholders to support a smooth implementation of modernized scores and advocate for additional reforms to the costly tri-merge credit reporting requirement. To increase competition and lower costs for consumers, MBA continues to urge the GSEs to adopt a single report option for GSE borrowers with strong credit profiles.”

Why it matters: MBA has consistently advocated for increased competition in credit reporting and scoring and welcomes reforms that will lower costs for consumers. Allowing lenders to choose either VantageScore 4.0 and FICO 10T should help accomplish the goals of added competition in the credit score space, increased credit availability, and reduced consumer costs.

Go deeper: In April, FHFA announced revisions to Fannie Mae and Freddie Mac selling policies to allow for the current use of VantageScore 4.0 and the future use of FICO 10T. The GSEs have since begun accepting mortgages assessed using VantageScore 4.0 through a limited rollout to approved lenders.

• HUD Secretary Scott Turner joined the April announcement, stating 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.

What’s next: MBA will continue to 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

FHFA Proposes New Duty to Serve Rule

FHFA recently released a proposed new Duty to Serve Underserved Markets rule that would repeal and replace the existing framework. The proposal is intended to give the GSEs greater flexibility to serve very low-, low-, and moderate-income families in the manufactured housing, affordable housing preservation, and rural housing markets by encouraging innovation and reducing administrative burden.

• The proposal would eliminate the current list of “prescribed activities” and instead allow each GSE to undertake any “eligible action” that advances its statutory Duty to Serve responsibilities, unless FHFA has determined the action to be ineligible through regulation or review. The proposal also would revise how median income is calculated, remove unnecessary conditions on eligible loan purchases, and streamline plan content requirements, as well as the evaluation and ratings process.

Go deeper: The proposal places a strong emphasis on chattel lending, recognizing it as the primary financing method for manufactured housing while noting the market remains underdeveloped due to limited liquidity, the lack of a securitization infrastructure, and insufficient performance data.

What’s next: MBA is reviewing the proposal and will be soliciting member feedback in the coming weeks. Comments are due by July 24, 2026.

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

MBA, Trades Respond to FHA’s MPR RFI

Last week, MBA and a coalition of housing trade associations submitted a joint comment letter in response to FHA’s Request for Information (RFI) on Single Family Minimum Property Requirements (MPRs).

• The letter urges FHA to modernize its property standards by aligning them with the collateral evaluation framework used by Fannie Mae and Freddie Mac (the GSEs), replacing prescriptive repair requirements with a more flexible, risk-based approach that focuses on a property’s overall condition and marketability.
• The recommendations also encourage FHA to leverage the upcoming implementation of UAD 3.6, consolidate fragmented guidance into a single handbook section, and use the FHA Drafting Table to solicit stakeholder feedback before implementing policy changes.
• Within the group’s recommendations, the coalition also provided prescriptive amendments that FHA should consider to align with the GSEs and the VA Loan Guarantee Program.

Why it matters: FHA’s current MPRs often require repairs for minor or cosmetic property conditions that can delay closings, increase costs, and make FHA-financed purchase contracts less competitive than conventional financing. Aligning FHA’s standards with the GSEs would maintain strong borrower protections while reducing unnecessary operational burdens and improving consistency for appraisers and lenders.

What’s next: MBA will continue to engage with FHA on this issue through its MBA Residential Loan Production Committee.

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

SCOTUS Issues Decisions Reshaping Independent Agency Executive Removals

Last Monday, the U.S. Supreme Court issued two opinions relating to a President’s power to remove executive officials.

• In Trump v. Slaughter, the Court in a 6-3 decision struck down a federal law that bars the president from firing members of the Federal Trade Commission (FTC) except in cases of “inefficiency, neglect of duty, or malfeasance in office.” On the same day in Trump v. Cook, the Court in a 5-4 decision held that Federal Reserve Governor Lisa Cook can remain in her job while challenging efforts to fire her.
• The Slaughter decision overturned the precedent of Humphrey’s Executor v. United States, 295 U.S. 602 (1935), and held that members of the FTC may be removed by the President at will, despite statutory “for cause” removal protections. However, the Court found that this holding does not extend to the Federal Reserve because of the United States’ long tradition of independent central banking.

Go deeper: The Court distinguished these holdings by observing that agencies which exercise executive powers must be controlled by the President. The Court noted that the FTC exercises regulatory, investigative, and enforcement authority and thus exercises these executive powers. The Federal Reserve, conversely, exercises “functions traditionally handled outside the Executive Branch” and “follows in the distinct historical tradition of the First and Second Banks of the United States – both of which influenced monetary policy and neither of which were subject to plenary Presidential control.”

• It is clear that a majority of the Court is unwilling to subject the Federal Reserve to the same degree of Presidential control imposed on other regulatory agencies.
• However, the holding of Slaughter raises questions regarding the viability of for-cause removal protections for officials who exercise similar executive authority. This could impact the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Securities and Exchange Commission, the Commodity Futures Trading Commission, and other multimember commissions.

What’s next: MBA will keep members informed about the impact of these decisions.

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

NMLS Ombudsman Meeting at AARMR: Submit Your Topics for August

Agenda items are now being accepted for discussion at the next National Multistate Licensing System (NMLS) Ombudsman meeting, which will be held on Tuesday, August 11, from 9 a.m. to noon PDT at AARMR’s 36th Annual Regulatory Conference & Training​ in Bellevue, Washington.

• Items must be submitted to ombudsman@nmls.org no later than 5 p.m. EDT on Monday, July 20^th, and will later be posted on the Ombudsman page​ of the NMLS Resource Center. Please note, those who submit a topic or their designee must attend the meeting in-person to present it.

Go deeper: MBA recommends member companies participate in each of the twice annual Ombudsman meetings, which are free to attend, and also register for the AARMR conference. MBA is currently collecting member feedback for any concerns it should raise on behalf of its members.

Why it matters: The NMLS Ombudsman meeting is an opportunity to discuss issues and topics with state regulators concerning NMLS, the State Examination System (SES), state licensing and supervision, and federal registration. Outside of the opportunity to present a topic of concern, the Ombudsman meeting itself provides a unique opportunity to understand the current state of the system and a constructive open forum for industry, regulators and the stewards of the NMLS.

What’s next: MBA staff will attend the AARMR conference and Ombudsman meeting and will brief members on any news or developments.

For more information or to provide suggestions for discussion at the meeting, please contact William Kooper (202) 557-2737 or Liz Facemire (202) 557-2870.

Federal Agencies Issue FDTA Final Rule

The financial regulatory agencies (collectively the Agencies) recently finalized the Financial Data Transparency Act (FDTA) Joint Data Standards rulemaking that establishes technical standards for data submitted to the Agencies to promote interoperability of financial regulatory information.

Why it matters: MBA previously submitted comments in response to the joint proposed rule. While MBA supported the adoption of consensus-based industry standards that are widely used by regulated entities, the proposed rule raised several concerns and questions about the methodology used by the agencies to designate various identifiers and terms as industry standards.

Go deeper: MBA supported adopting the Legal Entity Identifier (LEI) as the standard because it is already widely used across the mortgage industry. At the same time, MBA urged the agencies not to adopt the Financial Instrument Global Identifier (FIGI), citing concerns that it would not meet the needs of the financial services industry and would impose unnecessary costs on regulated entities.

• Importantly, the final rule adopts the LEI and declines to adopt the FIGI, consistent with MBA’s advocacy.

What’s next: MBA will monitor the implementation of this rule and communicate any updates to members.

For more information, please contact Rick Hill at (202) 557-2718 or Gabriel Acosta at (202) 557-2811.

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:

• Rethinking Income Strategies for Self-Employed Borrowers – July 8
• UAD 3.6 Office Hours Part II – July 20
• Analyzing the 2025 Mortgage Market: A Deep Dive into New HMDA Data – July 22
• The Black Line of Revenue: Building a Pipeline That Holds When the Market Shifts – July 27
• How Lenders Can Create More Homes – and Build Their Business – July 28
• Expanding Investor Opportunities Through Cash Flow Lending – August 4
• Driving Performance in Non-Agency Servicing – August 5

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.