A proposal to replace the longstanding tri-merge credit report with a single-file model has reignited debate over borrower costs and systemic risk, placing trade associations on opposing sides.
Supporters argue a single pull would encourage more predictive credit data and reduce systemwide costs without materially increasing risk in some cases, noting that mortgage servicing rights (MSR) investors already rely on a single representative score.
Its leading proponent, Mortgage Bankers Association (MBA) president and CEO Bob Broeksmit, said a “single-file framework promotes beneficial competition in the credit reporting space, encourages innovation, streamlines origination processes, and reduces borrower and lender costs that have seen dramatic increases in recent years.”
In terms of costs, research released in October by Amy Cutts, president at AC Cutts & Associates and former chief economist at Equifax and Freddie Mac, estimates a credit report costs $50 to $120 per borrower – and expenses tied to applications that did not result in originations totaled roughly $110 million to $225 million in 2023 and 2024.
Opponents counter that the tri-merge model protects borrowers by revealing errors or missing data across bureaus. They warn a single-file approach could enable score “gaming” by allowing lenders to avoid lower scores, and that would benefit lenders rather than consumers.
Eric Ellman, president of the National Consumer Reporting Association (NCRA) said we learned from the 2008 housing crisis that “more data is better than less data, especially when the financial stakes are so high.” He added, “The cost of being right for spending an extra $100 is so much stronger a case to make than the downside risk for a consumer who might lose thousands over the lifetime of a loan.”
At the center of the dispute is the fact that the three major credit bureaus do not receive identical data from creditors and lenders, raising questions about how eliminating files could affect risk across the mortgage ecosystem — including Fannie Mae, Freddie Mac and other investors — as well as borrower pricing.
Information asymmetry
Many consumers have thin credit files — or none at all — due to limited financial activity, while others have data reported to only one bureau. Because lenders and creditors are not required to furnish information to all bureaus, reporting across the system can be uneven.
“Our members compete all the time on data – the better data we have, the better our report is,” said Dan Smith, the president and CEO of the Consumer Data Industry Association (CDIA), a trade association representing the consumer reporting industry. “There’s no law requiring a lender to furnish it.”
Smith said reporting varies by institution: major banks and national credit card, mortgage and auto lenders typically report to all three bureaus, while smaller lenders, debt buyers, community banks, credit unions and alternative data providers may report to only one or two.
“There are also differences in the timing of when data is reported,” said Ellman. Federal rules help ensure consistency in furnished data, but no standard governs timing, and a one-size-fits-all report could leave lenders with an incomplete consumer picture, he added.
In a January white paper, the Community Home Lenders of America (CHLA) said each bureau is investing in different data: Equifax in utility and telecom data, Experian in rental data, and TransUnion in recurring consumer payments.
“Undisclosed debt risk increases with just one bureau, one score,” the CHLA wrote. “Gaming or score fishing will be incentivized. Lenders could pull 3 credit scores, but only deliver with 1 credit score, thus avoiding the inferior credit score.”
About 25% of tradelines are not reported to all three bureaus, according to credit-reporting and mortgage industry sources who are against a single file, though no formal study was provided.
Impacts on the loan level
Differences in credit reporting can lead to meaningful variation in consumer credit scores, ultimately affecting the price a lender offers a borrower, according to multiple studies.
A 2023 S&P analysis of roughly 23,000 residential mortgage-backed securities loans over the past decade found that the gap between a borrower’s highest and lowest bureau score averaged 25–30 points — enough to affect loan pricing and eligibility.
Score dispersion also varies by credit tier. The average difference between the highest and lowest scores in a tri-merge file is roughly 20 points for borrowers in the 800–825 range, compared with about 45 points for those in the 550–575 range. The study notes this may reflect adverse credit events, potentially tied to geography.
Separate research released in early February by the American Enterprise Institute, using ICE origination data for all first-lien purchase loans between 2019 and 2025, found that borrowers with scores above 700 have an average high-to-low spread of 26 points across bureaus.
Because of score variation, 31% of borrowers with a 700+ score could move up one loan-level price adjustment (LLPA) bucket by selecting the highest bureau score versus a tri-merge, 8% could move up two buckets and 4% could move up three.
Cutts’s October analysis also concluded that investors in mortgage-backed securities (MBS) would demand higher compensation for the risk from single-bureau reports. This could raise interest rates by 0.125% for every 20 points the score distribution shifts upward due to bureau selection, outweighing potential borrower savings from using a single bureau report.
The risk to the system
The AEI analysis focused on borrowers with credit scores above 700 — the same threshold proposed by Broeksmit for moving away from the tri-merge requirement. He noted the MBA’s 46-member Residential Board of Governors reviewed historical data on tradeline coverage, credit scores and loan performance before supporting a policy allowing a shift toward a single-file framework.
An MBA spokesperson said the report isn’t public but that members agreed that, with guardrails like limiting eligibility to borrowers above 700, the industry could transition to single-file reporting. The spokesperson also cited a Broeksmit blog urging Federal Housing Finance Agency (FHFA), Fannie and Freddie to refresh their own analysis of single-, bi- and tri-merge credit reporting to better inform the policy debate.
Under the MBA proposal, lenders could submit a single credit report for borrowers over 700, while those preferring tri-merge for competitive or risk reasons could continue using it.
The 700-score threshold reflects the strong credit quality of GSE loans. Public disclosures show average GSE scores around 757, roughly 75% above 740, and only about 6% below 680. MBA argues that requiring three files and scores is increasingly an “anachronism.”
AEI’s research, meanwhile, evaluates how score dispersion and reporting differences at this credit tier could influence default rates – or the risk to the system. It concluded that credit score performance is broadly similar across bureaus, with no meaningful differences in predicting loan outcomes.
“There’s certainly benefits of the tri-merge, but these benefits are a little bit small,” said Tobias Peter, senior fellow and the co-director of the AEI’s Housing Center, in a presentation of the results.