Bi-merge credit report: what it means for your loan team

The FHFA bi-merge credit report change forks your credit-pull step by loan type. A rule change that touches that step sounds small until you count the places your team has to remember to update: the LOS, the CRM, the borrower emails, the per-loan-type instructions in someone's head. That is exactly where files slip. What the expected FHFA bi-merge change actually does to a loan team's process, what stays the same, and how to run the transition without losing a deal to a missed step.

Quick answer: A bi-merge credit report uses two of the three credit bureaus (Equifax, Experian, TransUnion) instead of all three. FHFA is expected to direct Fannie Mae and Freddie Mac to accept bi-merge reports for conforming loans, with the announcement expected as soon as Oct. 12 at MBA Annual in Chicago and the change taking effect roughly one to three months later. FHA and VA loans still require tri-merge, so your team will run both frameworks depending on loan type.

Tri-merge vs bi-merge: what actually changes

A tri-merge report pulls data from all three credit bureaus; a bi-merge report uses two of them, and the lender picks which two. That is the whole mechanical change at the credit-pull step. The stated reason, per Ginsburg Law Group's borrower explainer, is to lower consumer and closing costs by ordering one fewer bureau report.

What you need to know on the news itself, so you can answer borrowers and referral agents this week without overstating it:

This is not new ground for FHFA. The bi-merge concept traces to a 2022 conservatorship directive, was aligned with new credit score models in 2024, and was postponed in January 2025 to a date to be determined, per FHFA's own credit scores page. The Oct. 12 timing is the restart, not the first mention.

Only conforming loans change: your process now forks by loan type

Bi-merge, if it lands, applies to conforming loans sold to Fannie and Freddie. FHA and VA do not follow. FHA said in May it will keep requiring tri-merge even as it expands approved scoring models, per National Mortgage Professional. VA loans also stay tri-merge, using the middle of three FICO scores (the lower of the two middle scores when there are co-borrowers), per VA Loan Network.

That fork is the real operational story, and it is the part every breaking-news piece skips. Today your credit-pull step is one step for every file. After bi-merge, a loan officer has to answer "what loan type is this?" before pulling credit, and route to a different process based on the answer:

A decision that used to be automatic is now a branch. Branches are where a step gets done the old way out of habit, or the new way on a file it shouldn't apply to, and nobody notices until an underwriter kicks it back. National Mortgage Professional made the same point in softer terms: credit becomes a bigger decision tree for loan officers once FHA and the GSEs diverge.

What changes in your LOS, CRM, and borrower comms

The credit pull itself is a settings change; the risk is everything downstream of it that references the old step. Certified Credit's lender FAQ notes bi-merge will require lenders to determine which bureaus they order from and may require updating POS, LOS, and pricing-engine settings. That is true, and it is the easy part because those are configured once.

The harder part is the dozen smaller places your process quietly assumes "three bureaus":

Miss one and you get an inconsistency: a borrower told one thing, a file processed another way, a loan officer on your team still pulling three out of muscle memory while the one next to him switched. During a transition, with guidance still firming up, those inconsistencies multiply. The underlying problem is the one that costs deals whenever any process step changes: the updates live in a human's memory, so some get made and some don't. If you've dealt with the related headache of LOS and CRM stages that don't match, this is the same leak wearing a new rule.

This is where a system that keeps the steps in sync earns its keep. SalesOS keeps your CRM and system steps aligned and flags files stalled on a step, so when the credit-pull process forks by loan type, the change propagates to the right place instead of depending on each person remembering it. It won't decide your credit policy or tell a borrower anything about their score; it keeps the process consistent so the rule change doesn't quietly cost you a file.

Manual transition vs a synced process

The difference shows up in how a change lands across a team, not in any single file.

None of this decides policy or picks your bureaus. It keeps the step your team actually performs the same across every file and every person, which is the whole fight during a transition.

Common pitfalls when the rule changes

The mistakes here are process mistakes, not credit mistakes. A few to watch for in the weeks around the announcement.

Acting before guidance lands. The announcement is not the start date. Changing your credit-pull step the day of the MBA keynote, before Fannie and Freddie publish implementation details, risks processing files under a framework that isn't in effect yet. Keep pulling tri-merge for conforming until the GSE guidance and transition period are real.

Changing the conventional step but forgetting FHA and VA stay tri-merge. If your SOP update says "we pull two bureaus now" without the loan-type fork, someone will shrink an FHA file to bi-merge and lose time fixing it.

Updating the LOS setting and nothing else. The settings change is visible; the CRM task language, the borrower emails, and the new-hire doc are the ones that rot. Those are the same places follow-up leaks, which is why 40% of leads never getting contacted and a botched process change share a root cause: a step that depended on memory.

Telling borrowers more than you know. Borrowers and referral agents will ask about it this week. A clean answer is: the rule is expected soon, it may lower credit-report cost, nothing on their file changes until it formally takes effect, and you'll apply it the moment it does. Stay off their specific score, rate, or qualification; that is advice you don't give based on a pending rule.

Letting loan officers improvise. In a small team, a new step often spreads by hallway conversation, which means three people doing it three ways. The fix is one documented process every loan officer follows for the same loan type, and a way to see which files are sitting on the credit step so an improvised one doesn't disappear into the pipeline.

FAQ

When does bi-merge actually take effect after the announcement? The change is expected to take effect one to three months after FHFA announces it, per Bloomberg reporting cited by HousingWire, not on announcement day. Until the GSEs publish formal guidance and a transition period, lenders keep pulling tri-merge for conforming loans.

Is bi-merge mandatory, and can my team still pull three bureaus? Whether bi-merge will be mandatory or optional for conforming loans is not settled, and FHFA has not published that detail, per WRE News. Treat bureau selection and whether you may still pull tri-merge as open until the GSE guidance names the rules.

Does bi-merge change FHA and VA loans too? FHA and VA loans still require a tri-merge report. FHA said in May it will keep tri-merge even as it expands scoring models, per National Mortgage Professional, and VA lenders pull a tri-merge using the middle of three FICO scores, so your team runs both frameworks depending on loan type.

Which two bureaus do we pull, and who decides? FHFA has not published guidance on how lenders would select the two bureaus, per WRE News, so the "which two" and "who decides per file" are not settled yet. Plan to document one standard choice for your team once the guidance lands rather than leaving it to each loan officer.

What should I tell borrowers asking about it this week? Tell borrowers the rule is expected to be announced soon, its goal is to lower credit-report cost by using two bureaus instead of three, and nothing on their file changes until it formally takes effect. Keep off their specific score, rate, or qualification, since that is advice based on a rule that isn't live.

When the credit-pull step forks by loan type, the cost isn't the policy change; it's the files that slip while your team updates a dozen places by hand. If you want the credit-pull step to stay consistent across your CRM, your LOS, and your borrower comms the moment the rule lands, book a demo and we'll map it to your actual process.