Advocacy Update: Lend Your Voice Now in Support of Ending the Tri-merge Requirement!

Lend Your Voice Now in Support of Ending the Tri-merge Requirement!

Recently, Federal Housing Finance Agency (FHFA) Director William Pulte made clear that significant changes to the mortgage credit reporting system are under consideration — including moving away from the costly and antiquated tri-merge requirement. Now is the time for MBA members to make their voices heard.

• In posts on X since last Thursday, Director Pulte has highlighted the high costs of the current credit reporting system and the impact those costs have on American consumers. He said FHFA is “strongly considering bi-merge, and stronger solutions,” and that the agency is “studying the use of just one credit report” to lower costs to consumers.

• On Wednesday, Director Pulte posted lender letters from the GSEs (Fannie Mae and Freddie Mac) confirming that all lenders will be able to originate and deliver loans using VantageScore 4.0. Also published were pricing grids for VantageScore 4.0, and Director Pulte clarified that all MBS and CRT issuances will include both VantageScore 4.0 and FICO scores.
• On Thursday, the Federal Housing Administration (FHA) announced January 1, 2027, as the implementation date for VantageScore 4.0 and FICO 10T adoption and shared a preparedness guide and technical resources to help mortgagees and industry partners prepare for the transition.

Why it matters: These comments and actions represent an important opportunity to advance credit reporting reforms that MBA has been working on for years: ending the GSEs’ universal tri-merge requirement and creating greater competition in the mortgage credit reporting market.

• MBA has consistently made the case that requiring lenders to obtain reports from all three credit reporting agencies limits competition and gives providers little incentive to compete on price or service. The result has been years of significant price increases that have raised costs for lenders and borrowers. And the pressure on costs continues. It will come as a surprise to nobody if additional price hikes are again on the table in the coming months.

As President and CEO Bob Broeksmit, CMB, said in a press statement on the expansion of the VantageScore 4.0 pilot, MBA also supports ending the tri-merge requirement and moving to a single-file approach for borrowers with strong credit profiles, which would further promote competition and reduce costs for consumers. These important updates, as well as the implementation of FICO 10T, will give lenders greater flexibility, enable more consumers to be scored accurately while maintaining prudent risk management, and expanding sustainable access to homeownership.

Act now: Director Pulte is signaling that FHFA is seriously considering changes to the status quo. Now is the time for MBA members to make their voices heard.

Using the hashtag #endtrimerge, tweet at Director Pulte or share your support on LinkedIn: ending the universal tri-merge requirement will increase competition and lower costs for consumers without compromising credit quality.

Help us turn years of advocacy into action!

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

MBA Coalition Urges FHA to Clarify VA Eligibility in VALID Act Disclosure

MBA and a coalition of housing and financial services associations recently sent a letter urging FHA to explain clearly the VA eligibility requirements in the Informed Consumer Choice Disclosure as it implements the VALID Act, recently enacted as Section 603 of the 21st Century ROAD to Housing Act.

Why it matters: The new law requires FHA to add VA loan pricing information to the disclosure but does not require lenders to determine whether a prospective FHA borrower is eligible for a VA loan. Presenting VA terms to a borrower that may not be eligible for VA financing could create consumer confusion and additional operational burdens for lenders.

What’s next: MBA will continue engaging with FHA on VALID Act implementation and submit additional recommendations for implementing elements of the 21^st Century ROAD to Housing Act (now Public Law 119-101) that affect residential real estate finance.

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

MBA Flags Significant Concerns on Proposed Colorado ADMT Regulations

Recently, MBA and the Colorado Mortgage Lenders Association (CMLA) submitted joint comments to the Colorado Department of Law (the Department) on its proposed rules to clarify and implement the Colorado Automated Decision-making Technology Act (ADMT Act).

• The state’s law defines an ADMT and establishes new requirements for both developers and deployers of ADMTs that are used to materially influence a consequential decision. It also gives consumers the right to request and correct inaccurate personal data used by ADMT as well as request human review of a decision.

Go deeper: Many of the Department’s proposed rules exceed the statutory mandate and would impose new and operationally complex requirements on deployers and developers. To protect consumers effectively, the final rules should be clear, practical, and capable of consistent implementation without duplicating existing federal compliance obligations. Without significant improvements, the ADMT Act rules risk creating unnecessary compliance burdens for lenders while increasing financing costs for the consumers the Act is intended to protect.

Why it matters: Following consultation with MBA residential committee members, the associations requested clarifying guidance and regulations to resolve the following industry concerns:

• Ensure that deployers do not need to send duplicative disclosures: Equal Credit Opportunity Act (ECOA) or Fair Credit Reporting Act (FCRA) and Colorado adverse action notices;
• Define and provide sector-specific examples of what constitutes a consequential decision;
• Create clear guidance for meaningful human review, including an explanation of when providing meaningful human review is not commercially reasonable; and,
• Provide clarifying responses and examples to questions around facilitating consumer rights to request personal information and correct incorrect information.

What’s next: The Colorado Department of Law will issue a revised proposal of the ADMT Act rules by September 23^rd. MBA and the CMLA will continue their advocacy collaboration, including participating in the October 26^th public hearing.

For more information, contact Liz Facemire, CMB (202) 557-2870 or Gabriel Acosta (202) 557-2811.

Please visit the MBA resource center mba.org/stateai for additional information on state AI activities.

MBA Advocacy Week & MAA Pre-Election Webinar

MBA Advocacy Week begins Monday, Sept. 14. Kicking off this key member engagement effort, MBA will host a free Mortgage Action Alliance (MAA) Pre-Election Webinar on Tuesday, Sept. 15, from 3:00–4:00 p.m. ET. Held on National Voter Registration Day, this briefing will provide an overview of the current congressional landscape, key midterm election races, critical federal deadlines, and the housing policy issues shaping the remainder of 2026 and the next Congress.

• Registration automatically establishes or renews a free annual MAA membership, providing participants with additional opportunities to stay informed and make their voices heard on federal policy issues. All registrants will also receive a recording of the webinar.

Why it matters: Decisions in the upcoming elections have the potential to re-shape congressional leadership, key committees, and the direction of federal housing policy. A clear read on this shifting landscape helps real estate finance professionals anticipate policy changes, understand how election outcomes could influence industry priorities, and engage more effectively with policymakers.

What’s next: MBA’s Annual Convention & Expo takes place Oct. 11–14 in Chicago, offering educational sessions, networking opportunities and additional ways to engage with MBA’s advocacy programs. Eligible Annual26 attendees can also join the inaugural Advocacy After Dark: MORPAC Reception on Sunday, October 11. The late-night, speakeasy gathering will bring together advocacy leaders, senior executives and industry influencers while supporting the work of MAA and MORPAC.

For more information, please contact Jamey Lynch at (202) 557-2818, Erin Reilly at (202) 557-2751, or Mike Fiegoli at (202) 557-2708.

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:

• Gain Confidence, Efficiency and Savings with Loan Product Advisor (LPA) – Sept.15
• Underwriting the New URAR: A Practical Walkthrough of UAD 3.6 – Sept. 17
• UAD 3.6 Office Hours Part IV – Sept. 21
• The Future of Mortgage Servicing: How Agentic AI Is Transforming Borrower Communications – Sept. 22
• More Regulation for Home Equity Investment Products? Emerging Federal and State Frameworks – Sept. 24
• Breaking into Non-Agency: A Strategic Playbook for Executive Leadership – Oct. 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.