The National Consumer Reporting Association (“NCRA”) had a rebuttal published in National Mortgage News, taking issue with comments made by Christopher Whalen in a Loan Think piece, Why credit score politics have nothing to do with lending (Oct. 14, 2025). NCRA’s credit report resellers play a critical role in the home loan process, opening doors for consumers to housing. Consumers and others must operate with facts. Unfortunately, Whalen’s Loan Think piece missed that mark, and the record needs to be corrected. 

Link: NCRA responds to Loan Think column on credit scores.

The National Consumer Reporting Association (“NCRA”) reseller members support competition and lower costs for American homebuyers. FICO’s announcement on score delivery this week may offer some relief, but more thorough review is needed.

The cost of credit reports and scores have increased significantly in the last few years, and that is a point of concern for NCRA members, who are price-takers, not price-makers. However, the cost of credit information is still less than 1% of closing costs.

The National Consumer Reporting Association (“NCRA”) filed a comment with the CFPB applauding the long-overdue review of its Larger Market Participant Rule (“Rule” or “LMP Rule”). NCRA has long been troubled by the larger market participant definition because the threshold is wholly out of synch with the definition of a small business established by the Small Business Administration (“SBA”). The CFPB’s definition, from an agency poorly positioned to define what constitutes a small business, jeopardizes small businesses nationwide.

NCRA makes three requests from the Bureau. First, the threshold for larger market participants in consumer reporting should be raised to $41, in line with SBA standards. Second, the Bureau should recognize the unique nature of resellers in consumer reporting when calculating annual receipts. Third, the Bureau should ensure a new Rule does not consider affiliate revenue unless (a) there is evidence that the consumer reporting agency (“CRA”) is circumventing the threshold by its affiliate structure, or (b) it is otherwise acting as a service provider to a larger market participant CRA.

In February 2025, President Trump directed federal agencies to review rules to “commence the deconstruction of the overbearing and burdensome administrative state.” His direction included a review of “regulations that impose significant costs upon private parties that are not outweighed by public benefits” and “regulations that impose undue burdens on small business[es] and impede private enterprise and entrepreneurship.”6 The threshold set in 2012 by CFPB in the Larger Market Participant Rule is a classic example of a rule that imposes substantial costs on private businesses with little or no public benefit and exacts significant burdens on small businesses.

Thankfully, on August 8, 2025, the Bureau published an Advanced Notice of Public Rulemaking (“ANPR”) “seeking information to assist it in considering whether to propose a rule to amend the test to define larger participants in the consumer reporting market established by the Bureau’s” LMP Rule. This review is long overdue.

IDIQ®, a leading financial intelligence platform, today announced a strategic partnership with the National Consumer Reporting Association (NCRA) that will transform how millions of renters build credit.  Through NCRA’s network of member agencies and their property management clients, renters nationwide will gain access to rent payment reporting services that will turn their largest monthly expense into a credit-building opportunity.

We are aware that FHFA Director Pulte posted on social media today regarding Fannie and Freddie’s decision to allow lenders to use the Vantage 4.0 Score, with no current requirement to build new infrastructure. He also supported the long-standing, tri-merge system.

Costs to consumers for housing are quite high, and mortgage reporting companies appreciate FHFA’s work to lower costs for consumers to attain the American dream of homeownership. Director Pulte’s focus on consumers is laudable. In general, increased competition benefits consumers by reducing costs.

We do not yet know the details of the FHFA decision, but the decision moves us in the right direction. Our reseller members stand ready to assist FHFA in implementing a smooth and seamless process for lenders and the consumers we all work to serve.
Our reseller members also support lenders who support adherence to the long-standing tri-merge system. Consumers may pay thousands more over a 30-year loan because a lender did not have a full picture of the consumer’s credit risk. Use of more credit and score information will be especially helpful to consumers at the margins. The FHFA decision will boost financial empowerment.

The cost of credit reports and scores has increased significantly over the last few years. The percentage increase is a point of concern for NCRA members, who are price-takers, not price-makers. However, the cost of credit information is still less than 1% of closing costs. The FHFA announcement could help curb or even reverse the cost increases.

The consideration of reducing three reports to just one credit report exposes lenders to increased risk. Increased lender risk was a contributing factor to the Great Recession of 2007-2009. NCRA urges FHFA to protect American consumers and not accept a single credit report for mortgage decisions.

We also see that Director Pulte and the President support allowing consumers’ rental payments to be considered towards using a mortgage. NCRA members have long advocated for more rental payment data to flow into the consumer reporting ecosystem. NCRA wants to see more consumers get the credit that they deserve. Data shows that when rent is included in a consumer’s credit score, those with the most to gain gain the most.

We are aware that the Mortgage Bankers Association (MBA) supports mortgage decisions based on a single credit report or score, contrary to long-standing guidelines and standards for a three bureau merged report (tri-merge). This change comes with a substantial risk to consumers, lenders, and the American economy.

A move to one credit report for mortgage decision-making would be a wrecking ball to financial inclusion, as more consumers will become unscorable. Consumers at the margins will be pushed out when they should be offered a chance to realize the American dream instead.

Consumers may pay thousands more over a 30-year loan because a lender did not have a full picture of a consumer’s credit risk.

The cost of credit reports and scores has increased significantly in the last few years, and that is a point of concern for NCRA members, who are price-takers, not price-makers. However, the cost of credit information is still less than 1% of closing costs.
The single-report mortgage report experiment exposes lenders to more risk. Increased lender risk was a contributing factor to the Great Recession of 2007-2009. NCRA urges FHFA to protect American consumers and not accept a single credit report for mortgage decisions.

In this episode of Financial Forward, host Jim McCarthy sits down with Eric Ellman, the newly appointed president of the National Consumer Reporting Association (NCRA), to explore the often-overlooked yet critically important world of consumer reporting agencies.

With more than 25 years of experience at the forefront of data policy and financial services—most recently with the Consumer Data Industry Association (CDIA)—Eric brings a unique lens to the complex network of companies that help banks, lenders, and employers make informed decisions. Now at the helm of NCRA, Eric is working to amplify the role of smaller, specialized consumer reporting agencies, particularly in the mortgage and tenant screening sectors.

Whether you’re a banker, a compliance executive, or a consumer navigating your financial journey, this episode demystifies how consumer data flows, what powers credit decisions, and how industry players are responding to growing regulatory scrutiny.

The NCRA President was a guest on the FCRA Focus podcast with hosts Dave Gettings and Kim Phan. The episode, Tenant Tales and Reseller Realities: Inside the FCRA Arena with Eric Ellman, discussed NCRA members’ legal challenges and opportunities.