MBA findings add pressure on tri-merge status quo

A switch from the industry’s standard tri-merge to a single-credit file could be done in such a way that loan-level price adjustment variations would be within acceptable limits, according to a new Mortgage Bankers Association study.

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The analysis of Intercontinental Exchange data from 105,000 loans originated in the first half of 2025 finds that within the range of 700-plus scores the MBA wants randomized moves to a single file limited to, the price would increase or decrease by, at most, one bucket.

The association specifically points to the 700-719 score band, within which it finds nearly 68% of loans would stay in the same loan price bucket while around 91% in total would either stay unchanged or move up or down one notch, with a roughly equal share of loans in each category.

“The findings suggest that a move to a single credit file would have minimal impact on credit risk or GSE pricing revenue,” the MBA wrote.

The association has been looking into the possibility with the aim of addressing members’ concern about what they say is a rise in the price of a tri-merge credit pull in the past few years from $30-$40 per loan to around $150 as the cost of required scoring also has increased.

Broader debate over single-file use

The new Mortgage Bankers Association research adds to debate over whether government-sponsored enterprises Fannie Mae and Freddie Mac should allow a less costly alternative to the tri-merge in a growing body of research on the topic. 

It follows an earlier Andrew Davidson & Co. report that came to a different conclusion in examining single- and bi-merge file alternatives, finding the score band changes involved to be intolerable even with the MBA’s suggested limits. That study examined 245 consumers’ data.

The Consumer Data Industry Association that represents the three major credit bureaus and many other players in that space has pointed to that report in its pushback against tri-merge alternatives.

In response to the mortgage banking group’s latest study, CDIA reiterated previous statements arguing for “more data, not less.”

“Requiring tri-merge reports across all acceptable scoring models ensures consistency, reduces risk, and preserves the integrity of the credit evaluation process for lenders, investors and borrowers,” the group said in an emailed statement.

Where the GSEs stand

Federal Housing Finance Agency Director Bill Pulte, who oversees the enterprises, decided not to immediately address the questions of whether an alternative to the tri-merge might be viable when he first announced plans to move ahead with other credit modernization.

However, he has shown concern about the lock the three major credit bureaus have had on the mortgage market in line with the administration’s focus on generating cost efficiencies, which Pulte has aggressively pursued in other policy actions.

While his attention is currently split between his FHFA role and other downsizing he’s been engaged as acting director of national intelligence, Pulte could revisit the possibility of a tri-merge alternative down the road.

President Trump has said that he does not plan to make Pulte the permanent national intelligence director but also had stalled efforts to name a replacement.

The GSEs have moved ahead with some credit-related policy actions while Pulte is juggling both roles, recently announcing long-awaited FICO data stakeholders can use to analyze the modernized 10T credit score.