FHFA and HUD Greenlight Credit Scoring Changes

On April 22, 2026, the Federal Housing Finance Agency (FHFA) announced that Fannie Mae and Freddie Mac (the Enterprises) will update their selling policies to allow a limited number of approved lenders to initially use VantageScore 4.0 credit scores. Lenders will maintain the option to use the Classic FICO model or VantageScore 4.0 with the tri-merge credit reporting requirement remaining intact. Separately, FHFA announced that it would allow for the future use of FICO 10T credit scores, with the publication of historical FICO 10T credit scores expected in summer 2026. The Department of Housing and Urban Development (HUD) also announced that the Federal Housing Administration (FHA) will allow the use of VantageScore 4.0 and FICO 10T in the coming months.

The announcement is a significant step in a long-running process that began in 2018 as part of the Economic Growth, Regulatory Relief, and Consumer Protection Act (P.L. 115-174), which included the Credit Score Competition Act and required FHFA to establish a process for validating and approving alternative credit scoring models for Enterprise use. The Enterprises have stated that FICO Score 10T and VantageScore 4.0, both approved and validated in 2022, are more predictive than Classic FICO and provide a more precise assessment of credit risk. The models incorporate certain additional credit data, such as rental and utility payment information, when that information is furnished to the credit bureaus.

Credit Scoring Changes

VantageScore 4.0

The Enterprises’ Credit Score Models and Credit Reports Initiative “Partner Playbook” outlines the changes for both Enterprises and provides a roadmap for the rollout. For a limited number of lenders, VantageScore 4.0 may be used once each Enterprise completes updates to its underwriting and selling/delivery systems. The Enterprises explain that the limited initial rollout is intended to:

• Validate end-to-end readiness across underwriting and selling/delivery systems and lender operations.
• Monitor performance and implementation outcomes as lenders onboard.
• Incorporate feedback and make adjustments as needed to support a smooth, scalable rollout.

The Enterprises note that lenders seeking to use VantageScore 4.0 should indicate their interest by contacting the respective Enterprise as outlined on their respective websites. Upon approval, participating lenders will be permitted to deliver either VantageScore 4.0 or Classic FICO scores. Although lenders are not required to deliver both Classic FICO and VantageScore 4.0 scores, they may obtain both scores through the Enterprises’ underwriting systems. The Partner Playbook further states that, with respect to lender choice, “FHFA and the GSEs will implement appropriate risk mitigants to ensure ongoing safety and soundness.”

FICO 10T

In addition to VantageScore 4.0, the Enterprises will update selling policies to allow for future use of FICO Score 10T credit scores. The Enterprises expect to publish FICO Score 10T historical credit scores

in the summer of 2026. The final rollout of FICO Score 10T will be available at a later date and the GSEs will provide advance notice to lenders.

Credit Reporting

The Partner Playbook states that the tri-merge credit reporting requirement will “not initially” change following the inclusion of VantageScore 4.0 credit scores. The Enterprises explain that by keeping credit reporting requirements stable, “FHFA is seeking to minimize the cost and complexity of this transition.”

This action reflects FHFA Director Bill Pulte’s previously stated position. In a July 2025 social media post, he detailed that the Enterprises will maintain the long-standing tri-merge requirement requiring lenders to pull credit reports from all three national bureaus. The decision reverses the agency’s prior plan, crafted under former Director Sandra Thompson, to move to a “bi-merge” two-bureau requirement starting in the fourth quarter of 2025. The agency opened a public comment docket on the change in March 2023 to gather industry feedback. After reviewing those comments, FHFA confirmed in February 2024 that the bi-merge standard would go forward. Implementation was scheduled for the fourth quarter of 2025 but never occurred.

Next Steps

The Enterprises’ Partner Playbook states that, in summer 2026, the Enterprises will publish historical FICO Score 10T credit scores for loans acquired between April 2013 and September 2025, as well as additional VantageScore 4.0 historical credit scores for loans acquired between April 2023 and September 2025. In the press conference announcing the changes, Director Pulte explained that the Enterprises will release separate pricing grids for VantageScore 4.0 loans. Additionally, when asked about potential adjustments to the Enterprises’ Loan-Level Price Adjustments (LLPAs), Director Pulte responded, “Stay tuned.”

Brownstein is closely monitoring developments related to mortgage credit scoring and housing policy more broadly and can assist clients in assessing policy risk, engaging with relevant stakeholders and navigating potential legislative or regulatory changes.

---

THIS DOCUMENT IS INTENDED TO PROVIDE YOU WITH GENERAL INFORMATION REGARDING NEW FEDERAL RULES ON CREDIT REPORTING FROM FHFA AND HUD. THE CONTENTS OF THIS DOCUMENT ARE NOT INTENDED TO PROVIDE SPECIFIC LEGAL ADVICE. IF YOU HAVE ANY QUESTIONS ABOUT THE CONTENTS OF THIS DOCUMENT OR IF YOU NEED LEGAL ADVICE AS TO AN ISSUE, PLEASE CONTACT THE ATTORNEYS LISTED OR YOUR REGULAR BROWNSTEIN HYATT FARBER SCHRECK, LLP ATTORNEY. THIS COMMUNICATION MAY BE CONSIDERED ADVERTISING IN SOME JURISDICTIONS.