Written by The Commonwealth Group
Underwriting guidelines change rapidly. For the most up-to-date information, please refer to the Fannie Mae Selling Guide at Selling Guide | Fannie Mae or for Freddie Mac at Guide Home. This post focuses on Fannie Mae requirements as they stand on November 1, 2026. The reported changes discussed below are not final policy. Nothing in this post changes what your team must do on today's loans.
Every few years, someone in Washington proposes to change how many credit reports a mortgage needs, and every few years the industry holds its breath. This fall, the conversation is louder than usual. Here is what is reported, what is actually in the Selling Guide today, and why an underwriting or QC team should care before anything is final.
What Has Been Reported
On October 1, HousingWire reported, citing a Bloomberg source, that the Federal Housing Finance Agency (FHFA) planned to direct Fannie Mae and Freddie Mac to accept two-bureau (bi-merge) credit reports in place of the three-bureau (tri-merge) reports they require today, with lenders able to choose which two bureaus to pull. A formal announcement was expected as soon as October 12, and the change was reported to take effect one to three months after it was announced.
As of October 19, the American Bankers Association's Banking Journal was still describing the matter as one FHFA was "considering." It reported that FHFA Director Bill Pulte had said the agency was considering requiring only one or two credit reports for loans the GSEs acquire, and that a decision on loan-level price adjustments (LLPAs) was anticipated before year end. In the sources we reviewed, we found no formal announcement. FHA, for its part, has adopted newer score models but kept the tri-merge requirement.
Treat all of this as a signal, not a rule.
What the Guide Requires Today
B3-5.1-01, General Requirements for Credit Scores requires lenders to request scores for each borrower when ordering the three-in-file merged report. The Guide is also specific about what happens when one repository has a problem:
Data from one repository is acceptable with a three-in-file merged report.
If a borrower's credit is frozen at one repository, the loan is acceptable if data is available from two.
If it is frozen at two or more, the loan is not eligible whether underwritten manually or in DU.
Lender QC has its own tri-merge dependency. Under D1-3-03, Lender Post-Closing Quality Control Reverifications, a random post-closing review must reverify credit history, and the Guide says to obtain a new tri-merge credit report to do it. Any change at the front of the process has to be matched at the back.
Putting Numbers to It: Why Two Bureaus Is Not Just "Cheaper"
The figures below are hypothetical. Under today's steps in B3-5.1-02, Determining the Credit Score for a Mortgage Loan, three scores produce the middle score and two scores produce the lower score. Whether those steps would carry over to a bi-merge world would be for Fannie Mae to say, but if they did, look at this borrower:
Three bureaus: 700, 688, and 672. The representative score is the middle score, 688.
Two bureaus, 700 and 688: the lower is 688. No change.
Two bureaus, 700 and 672, or 688 and 672: the lower is 672. The score drops 16 points.
The lower of any two of three scores can never be higher than the middle of all three. If the existing selection steps carried over, a two-bureau report could match a tri-merge score but could not beat it. Pricing tiers are set in score bands, so a handful of points can move a loan across a line. That is why lender choice of which bureaus to pull, if it arrives, will deserve a written policy rather than a loan officer's preference.
What Your Team Can Do Now
Change nothing on today's loans. The tri-merge requirement is still the rule until Fannie Mae says otherwise in a Selling Guide update or lender letter.
Map where "three" is hard-coded. Credit vendor ordering, LOS configuration, pricing engine inputs, pre-closing re-pull rules, and the QC reverification step all assume three bureaus.
Draft the policy questions early. Who chooses the bureaus, and on what basis? Is the choice consistent across borrowers and channels? What happens when one chosen bureau is frozen or thin?
Watch the official channels, not the headlines. The Selling Guide, Fannie Mae lender letters, and FHFA announcements are the sources that count. Reports of what might happen are not instructions.
Keep the VantageScore rules straight. The September change to VantageScore 4.0 already requires a request to all three repositories when a lender elects that model.
The "Why" Behind the Bi-Merge Watch
Why write about something that has not happened? Because the lenders that handle policy changes well are the ones who did their homework before the announcement. The cost of a change like this is rarely in the credit report itself. It is in the systems, the QC procedures, and the training that were all built around the number three.
The Commonwealth Group: Precision. Integrity. Results.
When policy is moving, the right partner helps you prepare without overreacting. At The Commonwealth Group, our contract underwriting and quality control teams track the official sources, tell you what is final and what is not, and update your review procedures the day a change becomes real. We do not just follow the guide; we know what to do when the guide is not enough.
Ready to go beyond the guide?
Contact Martin Luplow at The Commonwealth Group – info@thecommonwealth.net for more information on what our team of professionals in processing and underwriting can do for your company.
The Commonwealth Group – Innovative Services for the Mortgage Industry
West Beibers, CMB, AMP, CRU
Chief Executive Officer
The Commonwealth Group Companies