The Community Home Lenders of America has published a new list of reasons it views the effort it would take to transition to a single-bureau credit report option at the government-sponsored enterprises as outweighing benefits related to a potential reduction in expense.

"Costs will likely not be reduced — and could be increased," the CHLA, which is headed by Executive Director Scott Olson, wrote in an addendum to an earlier paper, flagging concerns about bureau differences that could mean greater risk and a need to still pay for three reports.

With newer scoring models incorporating more types of data, differences between them could grow because they will be increasingly likely to focus more on one type of payment track record than another to differentiate, the trade group said. The bureaus co-own one advanced score.

Differences in bureau data mean a single report could increase risk by leaving out information in the currently used tri-merge are a concern, according to the CHLA.

Also, the lack of a mortgage track record for a single report means parties whose pricing affects loan costs could change it, the trade group noted.

A separate legislatively mandated change aimed at modernizing GSE market score options has required a lot of effort to obtain data that shows how two new measures compare to the traditional one historically in order to make pricing stakeholders more comfortable with it.

The CHLA additionally showed concern that stakeholders like mortgage insurers could institute more varying requirements related to credit metrics than they would otherwise have if there were a single report option, noting that could lead to the need to still pay for multiple reports.

"While investors may pick one bureau/one score and require its use, some investors require different bureaus or scores. Lenders will then need to pull credit scores from all bureaus to determine best execution strategy," the trade group wrote.

A call for more independent study of the option

The CHLA report addendum follows the release of a separate white paper by an Interlinq Mortgage executive earlier this month, which suggests the single report still merits further analysis that should be done by objective researchers without ties to credit reporting agencies.

Some studies like one Standard & Poor's did back when the Biden administration was considering allowing the option of two rather than three reports concluded the average differences between the bureaus aren't significant. Research done for or by CRAs dispute this.

"We call for an unbiased, comprehensive study — conducted across multiple lenders, geographic areas, and scenarios — free from CRA influence," Eric Dee, chief operating officer, InterLinc Mortgage and president of the Texas Mortgage Bankers Association, said in her report.

Dee's report is critical of a white paper that Amy Crews Cutts, who has worked as an industry economist, wrote for one of the CRAs last year. In the report, which Equifax published in October, Cutts finds that a single-bureau credit report would be "misguided and expensive."

Cutts, who currently runs her own business and lists part-time affiliations with Primerica and the National Association of Credit Managers, last worked directly for Equifax in 2019, according to LinkedIn. She said she agrees there is a need for more study given some questions Dee raises.

Views on the MBA's proposal for 700+ scores

Dee pointed to an MBA proposal that would allow a single credit report only for borrowers with strong repayment histories and higher credit scores, instead of broadly replacing the industry's standard tri-merge.

Dee said Cutts' study focuses broadly on broad risks and does not take into account the proposal to limit scores to 700-plus as mentioned in a letter the MBA sent to the enterprises' conservator and regulator, the Federal Housing Finance Agency, in December. FHFA Director Bill Pulte has admonished the bureaus for not doing more about credit reporting costs.

"This targeted approach, urged in MBA's December 2025 letter to FHFA, could save $200 million annually while maintaining 95% accuracy," Dee wrote in her report.

Many GSE loans have had relatively high credit scores at origination recently, with the average pegged at 773 in a Federal Reserve Bank of New York report last year that analyzed data from its Consumer Credit Panel and Equifax 3.0 score. That compared to 726 for Department of Veterans Affairs guaranteed mortgages and 697 for those the Federal Housing Administration insures.

Cutts' study, which examines Standard & Poor's data, acknowledges average differences between the three bureaus vary by score range although she pegged the average variation at 29.

"The distribution range is wider the lower the bin," Cutts said in an email response to questions about Dee's report, acknowledging differentials are lower for higher scores. Higher scores also are designed to indicate greater likelihood of an ability to repay.

Cutts said has done to date suggests outside of the averages presented in the report "meaningful shares of consumers in every bin have 100+ point differences in their scores."

"I welcome criticism and understand sometimes it's personal because it affects livelihoods. Having good data to discuss the policy options is key," Cutts said. "I do think the interest in this is driven by stiff competition among lenders and large costs incurred by lenders to get potential mortgage clients."

Cutts said the data she's looked at to size these costs up to date has had its limits and may underestimate the concern. She said she could update her research at some point in the future.