Bob Broeksmit says tri-merge credit reports may soon disappear.

The Mortgage Bankers Association has signaled an industry shift away from traditional tri-merge credit reports, prompting the Federal Housing Finance Agency to evaluate alternative approaches. Tri-merge reports, long used to aggregate credit bureau data for mortgage underwriting, are being questioned for their timeliness and fit with modern risk frameworks. The MBA’s stance frames a push toward more flexible, bureau-specific reporting, enriched or permissioned consumer data, and updated vendor offerings. As FHFA weighs policy pathways and potential standards, lenders and aggregators face uncertainty around investor requirements, vendor contracts, and compliance processes. The signaling has already put operational readiness and change management near the top of lenders’ agendas as the market anticipates new documentation and verification norms.

A transition away from tri-merge reporting would ripple through origination, underwriting, pricing and secondary-market operations. Credit-scoring models, fraud-detection systems, and investor due diligence would need recalibration to ensure comparability and maintain credit quality. Vendors are likely to accelerate product development, while lenders must prioritize pilots, parallel testing and contractual revisions to avoid disruption. The regulatory review presents an opportunity to modernize data standards and consumer-consent practices but also raises issues of comparability, privacy and implementation cost. Market participants should engage proactively with regulators and counterparties, validate alternative data sources, and sequence systems changes to sustain underwriting reliability and investor confidence.

Key points
– MBA signals end of tri-merge: Industry association indicates a move away from aggregated three-bureau reports as a default tool for mortgage underwriting.
– FHFA weighing options: The regulator is reviewing policy pathways and potential standards to govern any transition.
– Drivers for change: Concerns over timeliness, data accuracy, modernization needs, and incorporation of permissioned or alternative data.
– Operational impacts: Lenders will need to revisit vendor contracts, underwriting systems, compliance controls and GSE eligibility processes.
– Market implications: Credit scoring, fraud detection, pricing and investor due diligence will require recalibration to preserve comparability and credit quality.
– Recommended actions: Engage regulators and counterparties, run parallel pilots, update technology and contractual terms, and validate new data sources and models.

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