The decades-old practice of requiring a “tri-merge” credit report – pulling data from all three major credit bureaus – for mortgage applications is facing renewed scrutiny. While long considered a safeguard for both lenders and borrowers, a growing chorus of industry voices is questioning whether the system is unnecessarily complex and costly, and whether a shift to a single or bi-merge approach could streamline the mortgage process without significantly increasing risk.
The debate centers on information asymmetry: the fact that Equifax, Experian, and TransUnion don’t all receive the same data from creditors. This means a borrower’s credit profile can vary depending on which bureau is consulted. Proponents of the tri-merge argue that this necessitates checking all three to get the most complete picture of a borrower’s creditworthiness. Opponents contend that the discrepancies are often minor and that focusing on a single, high-quality report can be sufficient, particularly for borrowers with strong credit histories.
Eric Ellman, president of the National Consumer Reporting Association, emphasized the lessons learned from the 2008 housing crisis. “More data is better than less data, especially when the financial stakes are so high,” he said, arguing that the cost of thoroughness is justified given the potential consequences for consumers. He pointed out that the cost of ensuring accuracy – an extra $100 – pales in comparison to the potential financial losses a borrower could face with an inaccurate or incomplete credit assessment.
However, the Mortgage Bankers Association (MBA) is leading the charge for change. The organization, representing 46 members on its Residential Board of Governors, believes a shift to a single-file framework is viable, with certain guardrails. Specifically, the MBA proposes allowing lenders to submit a single credit report for borrowers with scores above 700, while still permitting the use of tri-merge reports for those who prefer it or for riskier applicants.
This proposal reflects a growing belief that the benefits of the tri-merge diminish for borrowers with excellent credit. Research from the American Enterprise Institute (AEI) supports this view, finding that score dispersion – the difference between a borrower’s highest and lowest bureau score – is smaller for those with higher credit scores. AEI’s research, using ICE origination data from 2019 to 2025, showed that borrowers with scores above 700 have an average high-to-low spread of just 26 points across bureaus.
The potential financial implications of shifting away from the tri-merge are significant. A 2023 S&P analysis of roughly 23,000 residential mortgage-backed securities loans 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 is more pronounced for borrowers with lower credit scores, averaging around 45 points for those in the 550-575 range. This suggests that a single-pull approach could disproportionately disadvantage borrowers with less established credit histories.
a study released in February by the AEI found that 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. This highlights the potential for lenders to “game” the system by selectively choosing the bureau that provides the most favorable score, a concern raised by opponents of the single-file approach.
The Community Home Lenders of America (CHLA) has also voiced concerns, noting that each bureau is investing in different types of data – Equifax in utility and telecom data, Experian in rental data, and TransUnion in recurring consumer payments. The CHLA warned that relying on a single bureau could increase the risk of undisclosed debt and incentivize lenders to avoid lower scores.
TransUnion itself has weighed in, releasing a study in October 2025 that found that 4.4 million consumers could be adversely impacted by a single score pull, compared to nearly 2 million in the case of a bi-merge. The company argues that a single-pull environment creates a risk that strong borrowers will lose access to credit while at-risk borrowers find themselves in mortgages they can’t afford, potentially creating fresh risks for investors.
The debate also touches on the issue of data furnishing. Dan Smith, president and CEO of the Consumer Data Industry Association, explained that reporting varies by institution, with major banks typically reporting to all three bureaus while smaller lenders and alternative data providers may report to only one or two. This uneven reporting contributes to the discrepancies between bureau reports and underscores the challenge of creating a truly comprehensive single-file system.
Despite these concerns, the MBA argues that the current system is becoming an “anachronism,” particularly for borrowers with strong credit. The organization points to the fact that average GSE loan scores are around 757, with roughly 75% above 740 and only 6% below 680, suggesting that the benefits of the tri-merge are diminishing for a large segment of the market.
the future of credit reporting in the mortgage industry remains uncertain. The Federal Housing Finance Agency (FHFA) will likely play a key role in shaping the debate, and Fannie Mae and Freddie Mac’s continued requirement of tri-merge reports provides a significant degree of stability to the current system. However, as the cost of credit reporting rises and technology evolves, the pressure to modernize the process is likely to intensify.
