Real Estate Law · September 5, 2026 · 9 min read
The Federal Housing Finance Agency doesn't usually make headlines. Most people have never heard of it. But this week, FHFA signaled it's considering a switch from the industry-standard three-bureau credit report (called a "tri-merge") to a two-bureau "bi-merge" model—and, in the same breath, possibly green-lighting VantageScore as an alternative to the FICO scores that Fannie Mae and Freddie Mac have required for decades.
That's regulatory speak. Here's the plain-English version: if you're buying a home in Maryland, DC, Pennsylvania, or Delaware and your lender is selling your loan to Fannie or Freddie (which describes most conventional mortgages), the way your creditworthiness gets measured may be about to change. For some buyers, that's very good news. For others, it won't matter much. And for a few, it might actually be trickier.
Let me walk you through it.
Right now, almost every conventional mortgage lender pulls what's called a tri-merge credit report: your credit file from all three major bureaus—Equifax, Experian, and TransUnion—bundled into one document, with a FICO score from each. The lender takes the middle score of those three and uses that to decide your rate, your approval, and how much you can borrow.
Tri-merge reports cost lenders somewhere between $30 and $50 per borrower. That doesn't sound like much until you remember that every inquiry, every pre-approval, every rate-shop attempt triggers another pull. Those costs get baked into origination fees or passed along in other ways. And if one bureau has stale data or an error, you're stuck with it unless you can get it corrected across all three—which, as anyone who's disputed a credit report knows, is about as fun as a root canal.
The HousingWire article cites comments from Ryan Marshall, CEO of PulteGroup (one of the nation's biggest homebuilders), who told investors that FHFA is "moving forward" on both the bi-merge idea and VantageScore adoption. FHFA hasn't published a final rule yet, but the fact that a builder this size is talking about it publicly tells you the agency is well past the brainstorming phase.
A bi-merge report uses data from only two of the three credit bureaus. Lenders would still calculate a middle score, but now it's just the lower of the two scores pulled (since there's no third number to compare). The idea is to cut costs, speed up underwriting, and reduce the chances that a single bureau's mistake torpedoes your loan.
Sounds reasonable. And for many Maryland buyers, it will be. But here's the catch: if you happen to have a significantly better score at the bureau that gets left out, you could end up with a worse qualifying score than you would under the old tri-merge system. It's not common, but it's possible—especially if you've recently paid off a collection or had a dispute resolved with only one or two bureaus.
The other half of the announcement is VantageScore. Most of us have never seen our VantageScore, even though the three bureaus created it years ago as an alternative to FICO. VantageScore weighs your payment history and credit mix a little differently, and it can generate a score even if you have a thinner credit file. That's a big deal for first-time buyers, immigrants, and younger borrowers who don't have decades of credit cards and car loans behind them.
If FHFA allows Fannie and Freddie to accept VantageScore, it opens the door for lenders to offer you a choice: qualify under FICO or VantageScore, whichever works better. That could mean the difference between approval and denial for some Harford County or Prince George's County buyers I work with who are building credit from scratch.
Let's get specific.
First-time buyers with thin files. If you've been renting, paying your phone bill and student loans on time, but you've never had a credit card or auto loan, your FICO score might be low—or nonexistent. VantageScore can sometimes generate a usable number where FICO can't. I've had clients in Anne Arundel and Howard counties who were stuck in limbo for months because they were "credit invisible." This change could pull them into the market.
Buyers who've recently cleaned up their credit. If you paid off a medical collection or settled an old account and one bureau updated quickly but the others lagged, a bi-merge model might help you if the slow bureau gets dropped. It's a gamble, but it's a new option.
Lenders and builders. Faster, cheaper credit pulls mean faster pre-approvals and closings. That's why PulteGroup is paying attention—anything that shortens the cycle time between contract and closing helps them move inventory. For you as a buyer, it could mean fewer delays and lower fees.
Buyers with uneven credit across bureaus. I've seen this more than once: a client's Equifax score is 720, Experian is 680, and TransUnion is 700. Under tri-merge, they qualify with a 700. Under bi-merge, if Equifax gets dropped, they're stuck with 680—and that might cost them a quarter-point on their rate or even disqualify them from certain loan programs. You won't know which bureaus your lender will use until FHFA finalizes the rules, so check all three of your reports now and dispute any errors everywhere.
Anyone shopping lenders. If half the lenders in Maryland adopt bi-merge and the other half stick with tri-merge (which is likely during any transition period), your qualifying score could be different depending on where you apply. It's going to get confusing. Ask your lender—or ask me—which scoring model they're using and which bureaus they pull.
Technically, nothing yet. FHFA has not published a final rule. What we have is a public comment from a major builder saying the agency is "weighing" these changes and that the industry expects them soon. That's significant because FHFA moves slowly; if they're talking about it in investor calls, it's real.
You can track FHFA's official rulemaking at www.fhfa.gov. When they do publish a proposed rule, there will be a public comment period—and you can bet every lender, credit bureau, and housing advocacy group in the country will weigh in.
In the meantime, Fannie Mae and Freddie Mac still require tri-merge FICO scores for all loans they purchase. That's the law of the land until FHFA says otherwise.
Pull all three of your credit reports. You're entitled to one free report per year from each bureau at AnnualCreditReport.com. Do it today. Look for errors, late payments that aren't yours, accounts you didn't open. Dispute anything that's wrong at all three bureaus, not just one.
Check your VantageScore. Some credit-monitoring apps (Credit Karma, for example) show you a VantageScore for free. Compare it to your FICO scores. If your VantageScore is significantly higher, this rule change might help you. If it's lower, you'll want to stick with FICO—and you'll want to make sure your lender knows that.
Talk to your lender before you lock a rate. Once FHFA's rule goes live, ask which scoring model your lender will use and which bureaus they'll pull. If you're right on the edge of a rate tier or loan limit, this could matter a lot. I've written before about rate lock extensions and how construction delays or paperwork snags can cost you—well, a surprise credit-score change can do the same thing.
Don't panic if you're already under contract. If your lender has already pulled your credit and issued a pre-approval or commitment letter, you're grandfathered under whatever rules were in place when they pulled it. FHFA rule changes apply to new loans, not loans already in process.
Each of our state housing markets has its quirks, but we all share one thing: most buyers here use conventional loans backed by Fannie or Freddie. FHA and VA loans have their own credit rules (and their own scoring models), so this change won't touch them directly. But if you're buying in Baltimore County, Montgomery County, York County, or New Castle County with a conventional loan—especially if you're stretching to hit a debt-to-income ratio or trying to avoid PMI—your credit score is everything.
I've worked with teachers, nurses, and tradespeople across this region who had great incomes and solid down payments but got stuck because one late payment from five years ago dragged their score below 680. If VantageScore gives them a second path to qualification, that's a real win.
On the other hand, I've also seen buyers get overconfident because some app told them their score was 740, only to discover their mortgage score was 690. This rule change makes that confusion worse, at least in the short run, because now you might have two different scoring models in play.
This credit-score news arrives in the middle of a much bigger regulatory earthquake. As I've written about before, the NAR settlement and new buyer-agency rules have already changed how we talk about commissions, write offers, and show homes. Now FHFA is changing how lenders qualify you for the loan that pays for those homes.
Everything is in motion right now. Some of it helps buyers. Some of it helps sellers. A lot of it just creates paperwork and confusion until the dust settles.
That's why you hire a REALTOR® who actually reads the rule changes and explains them in English instead of jargon. It's also why I spent twenty years in education before I ever sold a house—because teaching people how the system works is more valuable than just steering them through it.
This is general information, not legal advice—for your specific situation, please consult a licensed real estate attorney. Credit law, fair lending rules, and mortgage underwriting standards are complicated, and every buyer's situation is different. If you think a credit bureau has violated the Fair Credit Reporting Act or a lender has treated you unfairly, talk to a lawyer who specializes in consumer credit. I can help you buy a house, but I can't represent you in a legal dispute.
And if you're reading this because you're trying to figure out whether now is the time to buy in Harford, Cecil, Howard, or any of the other counties I serve—or whether you should wait to see how all these rule changes shake out—let's talk. I won't pretend to have a crystal ball, but I can walk you through your actual numbers, your actual credit situation, and what homes are actually available today.
Mortgage rates are sitting at 6.71% this week, according to Freddie Mac's latest survey. They're not falling anytime soon, and inventory is finally starting to climb after years of nothing. If your credit is solid—or if this new VantageScore option might make it solid—there's no reason to sit on the sidelines waiting for perfection.
The rules are changing. The market is moving. And the buyers who do their homework and get their credit house in order are the ones who'll come out ahead.
Katrina Kirton Sherrod, REALTOR® · Samson Properties · Licensed in MD, DC, PA & DE · 443-616-9770 · Katrina@kkstherealtor.com
“Don’t wait to buy real estate. Buy real estate and wait.” — Will Rogers (attributed)