Last week the Community Home Lenders of America updated a 2024 white paper to make clear that it opposes a “Single Credit Bureau Pull model due to many unresolved issues and concerns,” including :

1. Costs will likely not be reduced – and could increase [as explained below]
2. A Single Bureau Credit Pull model could disadvantage veterans, rural families, and first-time homebuyers – if FHA, RHS, and VA don’t adopt this approach. If this occurs, it will discourage lenders from using these critical low down payment loan programs, due to the cost of doing more credit pulls these programs may require.
3. Costs could increase for consumers that shop for mortgage rates. If one lender uses one score, one bureau – and another competing lender uses a different one –
   the borrower could potentially be charged two upfront credit charges to see the pricing differences between the two lenders.
4. A switch to a single bureau model could make it harder for aggregator/investors to price loans – leading to risk premiums in loan pricing that raise rates. The lack of data on pricing of MSRs during the transition period could create risk and uncertainty – which will be priced into loans, as we saw during the COVID crisis.
5. Pricing uncertainty will increase based on what score and what bureau the lender uses. Lenders already expect three pricing grids: one for FICO Classic, one for VantageScore, and one for FICO 10T. Not all data sources report to all three bureaus. Thus, undisclosed debt risk increases with just one bureau, one score. This could also lead to greater repurchase risk for lenders, if they use a score that misses debt, other problems.
6. A lack of coordination among the major federal housing regulators (FHA, RHS, VA, and FHFA), could complicate this model greatly – just as it did under the subsequently abandoned bi-merge proposal of the Biden Administration. This would significantly undermine any benefits of a Single Credit Bureau Pull model. FHFA, FHA, VA and RHS today do not work together on credit score reforms, and no other federal entity seems likely to coordinate them or order them to do so.
7. 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. This could also lead to greater repurchase risk for lenders.
8. Concerns about how Mortgage Insurers (MIs) will view and price in response. MIs may assume a gaming system and price accordingly.
9. 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 CHLA work was picked up in a HousingWire story, Lenders group flags risks in single-bureau credit plan.