On the Hill is NAMB's bi-weekly read on what's happening in Washington and why it matters to mortgage brokers.
Each issue cuts through the noise to bring you the federal policy, legislation, and regulatory moves shaping your business, along with the context and action items you need to stay ahead.
Brought to you by the National Association of Mortgage Brokers, the voice of the broker community since 1973. |
Credit reporting is the story of the fortnight. The FHFA is widely reported to be close to letting lenders pull two credit reports instead of three, FHA locked in its rules for newer credit scores, and mortgage rates kept climbing. Meanwhile the UAD 3.6 deadline is less than three weeks away. Here's what brokers need to know. |
LEAD STORY: Tri-merge may be on its way out, but nothing is official yet |
Bloomberg reported on October 1 that FHFA Director Bill Pulte plans to let Fannie Mae and Freddie Mac accept "bi-merge" credit reports, meaning lenders would pull two of the three bureaus instead of all three. Bloomberg's source said the change could take effect one to three months after it is announced.
The widely expected announcement at the MBA Annual in Chicago did not happen on schedule: Pulte pulled out of his in-person appearance on Monday, October 12, and was set to speak virtually the next day. As of this writing we have not found an official FHFA announcement. MBA's CEO told the conference that tri-merge "won't be around for long," while he said the exact reform is still being worked out. Pulte has also said the FHFA is looking at a single-pull option, and that the GSEs would use one pricing grid that treats VantageScore 4.0 the same as Classic FICO.
Why it matters: credit report costs are one of NAMB's stated priorities, and brokers are the ones who feel those fees on every file. A move to two bureaus could lower costs and change how you order and deliver reports. It could also raise questions about loan repurchase risk, which community lender groups have flagged. Do not change your credit workflow until the FHFA publishes the details and effective date. NAMB will report as soon as there is something official.
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FHA puts its alternative credit score rules in writing
On October 9, FHA issued a mortgagee letter formalizing the use of VantageScore 4.0 and FICO Score 10T alongside Classic FICO. The rules apply to FHA case numbers assigned on or after January 1, 2027. The existing minimum decision scores of 500, 580, and 620 stay in place. If a lender submits more than one score model, each one must independently come back with an accept recommendation for the loan to be accepted overall. FHA also still requires three credit reports on single-family loans, so the bi-merge talk at the FHFA does not change FHA yet. FHA has released a preparedness guide for lenders.
For brokers: ask your FHA lenders which score models they plan to accept on January 1, and whether they will run more than one. More models can open doors for some borrowers, and it can also mean more ways for a file to fail.
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HUD leaders tell lenders they want lower costs and more participation
At the MBA Annual, Ginnie Mae President and acting FHA Commissioner Joseph Gormley and FHA's Matt Jones, who is President Trump's nominee to lead the agency, spoke for nearly an hour about lowering industry costs, drawing more lenders and private capital into government-backed lending, and housing supply. The detailed reporting is behind a paywall, so specifics are thin for now. NAMB will watch for follow-up policy.
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UAD 3.6 mandate lands November 2
The GSE mandate for the new appraisal format takes effect November 2. As we reported last issue, lenders that cannot be ready may request a one-time exception from each GSE, which is not automatic. Approved lenders can keep using UAD 2.6 through May 19, 2027, but lose some appraisal rep-and-warrant relief starting March 1, 2027. NAMB President Mike Farrell spoke about the rollout in a recent Scotsman Guide interview. Now is the time to confirm where your wholesale and correspondent partners stand, since their readiness decides which format your appraisals need.
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FHFA cuts the budget of its own inspector general
Pulte announced deep cuts to the FHFA Inspector General's office on September 30. The acting deputy inspector general told Congress it would mean laying off roughly 40 investigators, a team credited with more than 1,200 criminal convictions and nearly $75 billion in recoveries. Pulte says the office costs more than comparable watchdogs at other agencies. Senate Banking Committee Democrats have demanded a reversal, and reports note the office is reportedly looking into Pulte himself.
Why brokers should care: the IG is a main check on fraud and misconduct at the agency that sets GSE rules for the whole industry.
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Condo rules: no change, January 4 still on the calendar
We found no new FHFA action on Fannie Mae Lender Letter LL-2026-03 this fortnight. Limited Review was retired on August 3. The higher HOA reserve requirement, from 10% to 15% of the annual budget, is still set for January 4, 2027. FHFA told reporters the GSEs are implementing on time and has not acted on NAMB's June 15 request for a delay of at least 12 months. NAMB's white paper, state-by-state analysis, and social media kit remain available for members.
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Johnson nomination still waiting on the full Senate
The Senate Banking Committee advanced Brian Johnson's nomination to lead the CFPB on September 17, by a 13 to 11 party-line vote. We have not found a report of a floor vote since. Mark Paoletta remains acting director. LO compensation and RESPA servicing reform remain the rulemakings to watch.
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30-year fixed: 7.40% (Freddie Mac PMMS, October 8), up from 7.28% the week before and 6.30% a year ago.
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15-year fixed: 6.73% (October 8), up from 6.60% the week before.
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What your association is focused on:
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Credit costs: NAMB continues to push for credit report and credit score cost relief, and the bi-merge news shows the issue is moving.
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Condo financing: NAMB's request for a delay on the HOA reserve change is still on the table with the FHFA.
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Veterans' lending: the H.R. 9237 call to action is live at namb.org/call-to-action.
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Ongoing: LO comp reform, LLPA reduction, flood insurance improvements, and expanded affordable housing access remain 2026 priorities.
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Any day: an official FHFA announcement on bi-merge, including the effective date.
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Nov 2, 2026: GSE UAD 3.6 mandate takes effect.
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Dec 11, 2026: next federal funding deadline.
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Jan 1, 2027: FHA alternative credit scores (VantageScore 4.0, FICO 10T) apply to new case numbers.
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Jan 4, 2027: condo HOA reserve requirement rises from 10% to 15%.
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Mar 1, 2027: UAD 2.6 exceptions lose some rep-and-warrant relief.
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May 20, 2027: mandatory UAD 3.6 use for all new submissions.
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