Key Takeaways
- The two-report requirement is a reported plan: one Bloomberg story dated October 1, 2026, citing one unnamed person. October 12 is only the earliest date that source gave for a possible announcement.
- As of October 5 the Fannie Mae Selling Guide still requires lenders to request a three in-file merged credit report, and the FHFA credit scores page, last updated October 2, lists no two-report change.
- The Selling Guide rule as written now: three scores, take the middle; two scores, take the lower. On a 702/718/741 file that gives 718 with all three reports, and 702, 702 or 718 across the three possible pairs.
- Those results are the current rule applied to a hypothetical, on one file. No document says which two bureaus would be pulled, who would choose them, or whether lower-of-two would be kept.
- The middle-of-three rule drops a single low outlier and lower-of-two keeps it. The fewer reports in the pull, the more any one report, and any error on it, can decide.
- The preparation is the same with or without an announcement: get all three reports, compare them account by account, and dispute errors with the bureau that shows them before applying.
A Report About a Plan, Not a Rule
All of that is a reported plan. As of October 5 there is no new FHFA document announcing or ordering that change, and the Fannie Mae Selling Guide still requires lenders to request a three in-file merged credit report.
Nothing has changed, so there is no new rule to explain. Instead I take one file, with bureau scores of 702, 718 and 741, and run it through the score-selection rule that sits in the Selling Guide right now: once with all three reports, then once with each possible pair. That is the current rule applied to a hypothetical, and it describes one file. No document says what the rule would be if two reports became the requirement.

Everything That Is on Paper as of October 5
bi-merge
A mortgage credit report built from the files of two of the three nationwide credit bureaus.
Announced Once in 2022 and Never Put in Force
Neither version ever took effect. FHFA aligned the two-report change with the planned transition away from the Classic FICO model on February 29, 2024, and on January 16, 2025 the implementation date moved from the fourth quarter of 2025 to a date to be determined. An interim policy of July 8, 2025 let lenders use either VantageScore 4.0 or Classic FICO, delivered through the three-bureau report.
October 24
FHFA validates two newer scoring models and says Fannie Mae and Freddie Mac will work toward a two-report requirement.
February 29
The two-report change is aligned with the planned transition away from Classic FICO.
January 16
The implementation date moves from the fourth quarter of 2025 to a date to be determined.
July 8
Interim policy: lenders may use VantageScore 4.0 or Classic FICO, delivered through the three-bureau report.
September 3
Director Bill Pulte posts on X that the agency is seriously considering bi-merge.
October 1
Bloomberg reports, citing one unnamed person, that a two-report directive is planned.
The Rule in the Selling Guide Now: Middle of Three, Lower of Two
representative credit score
The single score Fannie Mae assigns to a loan after selecting one score for each borrower.
The selection starts with each borrower, who ends up with a single score. When three credit scores are obtained, the lender chooses the middle one; when two are obtained, the lower one. The guide's own tie example is 700, 680, 680, which gives 680. If there is more than one borrower, the lowest of the borrowers' single scores becomes the representative score for the loan.
The two-score case is already written down. Fannie Mae recommends obtaining at least two scores for each borrower, and a separate topic accepts a report when a borrower with traditional credit has a file frozen at one bureau, as long as credit data is available from two bureaus and the lender requested the three-bureau report. That means lower-of-two already applies when a file returns only two scores.
One 702/718/741 File, Run Four Ways
The file has one borrower and one scoring model, and its three bureau scores are 702, 718 and 741. I am calling the bureaus A, B and C in that order, because no document says which two bureaus would be pulled under a two-report requirement, or who would choose them.
Applying the Selling Guide as written:
- All three reports (702, 718, 741): three scores, so the lender takes the middle one. The representative score is 718.
- Bureaus A and B only (702, 718): two scores, so the lower one, 702.
- Bureaus A and C only (702, 741): the lower one again, 702.
- Bureaus B and C only (718, 741): the lower one is now 718.
One 702/718/741 File Under the Rule as Written Now
| Reports | Rule | Result |
|---|---|---|
| A, B and C | Middle of three | 718 |
| A and B | Lower of two | 702 |
| A and C | Lower of two | 702 |
| B and C | Lower of two | 718 |
702, 718 and 741 under the current rule
With all three reports the file is a 718. Two of the three possible pairs make it a 702, and the third leaves it at 718. One file, one scoring model, the Selling Guide as written now.
In all four runs the 741 is never the representative score: under the middle rule it is set aside as the high number, and under lower-of-two it always loses to its partner. The 702 moves the other way, from not counting at all to being the answer in two of the three pairs. With three reports the lowest number is set aside along with the highest, and with two there is nothing to set aside. The outcomes span 16 points, from 718 down to 702, and no pair produces a number above 718.
That last point is arithmetic and holds for any three numbers: the lower of any two is either the middle or the lowest of the three. It follows from the rule as written now and cannot serve as a forecast, because the rule that would apply to a two-report requirement has not been written.
Why One Report Matters More When Fewer Are Pulled
Suppose bureau A read 698 instead of 702. With three reports the middle is still 718 and the band is still 1.375%; the 698 is set aside and never touches the price. Under lower-of-two, either pair that includes bureau A returns 698, which falls in the 680 to 699 band at 1.750%. The gap on that row is 0.375 percentage points, and the only thing that differs is which reports were in the pull.
I am inferring that my three numbers differ because the three bureaus do not hold identical files on me; no document here says why this file's scores differ. If one bureau's file contains a mistake, a middle-of-three rule gives some cushion, because one low outlier is dropped. The cushion is partial: an error at the bureau that happens to sit in the middle counts either way. Under lower-of-two there is no cushion at all, and whatever the lower report produces is the answer.
Nothing here measures how many points an error costs. The file shows only that the fewer reports in the pull, the more any single one of them can decide.
What No Document Says, and Who Wants What
As of October 5 no document says whether a directive will be issued at all, which two bureaus would be pulled, or whether the lender, the borrower or the rule would pick them. None says whether lower-of-two survives, when any of it would take effect, or whether three reports would remain an option.
"Fannie Mae and Freddie Mac now require only two credit reports."
As of October 5, 2026 no new agency document orders it. One Bloomberg story, citing one unnamed person, reports that a directive is planned.
Why It Matters
The Fannie Mae Selling Guide still requires lenders to request a three in-file merged credit report. A two-report change was first announced on October 24, 2022 and has never been put in force.
What to Check Now, Whatever Is Announced
With a file like this one, in the week before a possible announcement, I would do what I would do if no story had run.
Then ask the loan officer which scoring model is being used on your loan; on loans sold to Fannie and Freddie, the lender chooses it. Also ask which bureaus are in the credit report being ordered. As of October 5 the Fannie Mae rule on paper is that the lender requests all three.
What to Check Before a Mortgage Application
None of these steps depends on October 12. Checking all three is the right preparation under a three-report rule or a two-report rule, because you cannot know in advance which report will end up deciding.
Under the rule in force, with scores from the three-file merged report the guide requires lenders to request, the 702/718/741 file is a 718. Under the same rule fed only two reports, it is a 718 once and a 702 twice. That is all the walkthrough shows.
It cannot show what happens next. One person told Bloomberg that a directive is planned and that an announcement could come as soon as October 12. FHFA's own page, updated a day after that story, does not say so, and the two-report change announced in 2022 is still not in effect.
If something is announced, read the document for which reports are required, which score-selection rule applies, and what date it takes effect. As of October 5 there is no new FHFA document announcing or ordering a two-report change, and the Fannie Mae Selling Guide still requires lenders to request all three reports.
Frequently Asked Questions
1. Have Fannie Mae and Freddie Mac switched from three credit reports to two?
No. As of October 5, 2026 there is no new Federal Housing Finance Agency document ordering it. Bloomberg reported on October 1, citing one unnamed person familiar with the plans, that the agency is planning to direct the two companies to require credit data from two bureaus instead of three. The Fannie Mae Selling Guide still requires lenders to request a three in-file merged credit report.
2. Is October 12 the date a two-report rule takes effect?
No. October 12 is the earliest date the Bloomberg source gave for a possible announcement, tied to a mortgage industry conference in Chicago where the agency director is listed as a speaker. HousingWire, relaying Bloomberg, said the requirement is expected to take effect one to three months after it is announced. Neither date appears in any agency document.
3. How does a lender turn three credit scores into one for a Fannie Mae loan?
Under the Selling Guide topic dated April 22, 2026, each borrower gets a single score: the middle one when three scores are obtained, and the lower one when two are obtained. With more than one borrower, the lowest of those single scores is the representative credit score for the loan. That score is used for pricing on all loans.
4. What would a 702/718/741 file be with only two reports?
Applying the rule as written now, the pair 702 and 718 gives 702, the pair 702 and 741 gives 702, and the pair 718 and 741 gives 718. With all three reports the same file is a 718. No document says that lower-of-two would be the rule under a two-report requirement.
5. Would my mortgage score be lower if only two reports were pulled?
Nobody can say, because the rule that would apply has not been written, and no document says which two bureaus would be used or who would choose them. The only arithmetic available is about the rule as written now: the lower of any two scores is either the middle or the lowest of the three, never the highest.
6. Why does an error at one bureau matter more when fewer reports are pulled?
With three scores and a middle rule, one low outlier is set aside and does not decide the result. With two scores and the lower-of-two rule in the Selling Guide now, whatever the lower report produces is the result. The fewer reports in the pull, the more any single report can decide. This says nothing about how many points any error is worth.
7. Was a two-report requirement not already approved in 2022?
A two-report change was announced on October 24, 2022. The agency news release that day said Fannie Mae and Freddie Mac "will require lenders to provide credit reports from two of the three nationwide" bureaus. It was never put in force. In January 2025 the implementation date was changed to a date to be determined, and a July 2025 interim policy kept the three-bureau report.
8. What should I do before applying for a mortgage this fall?
Get your reports from all three bureaus, compare them account by account, and dispute any error with the bureau whose report shows it, well before you apply. Then ask the loan officer which scoring model and which bureaus are being used on your loan. That preparation is the same whether or not anything is announced.