FICO’s Adoption and Pricing in the Mortgage Origination Market
At $3.50 per score, FICO royalties constitute only 15% of the cost of a $70 tri-merge credit report and 2/10ths of one percent of mortgage closing costs
For decades, thousands of lenders and other participants, from credit unions and community banks to the nation’s largest lenders and investors, have freely and voluntarily selected the FICO® Score as the independent, predictive, and reliable measure of consumer creditworthiness in the United States. They have done so because FICO pioneered the development of credit scores and was the first company to provide consumer credit markets with a tool for evaluating borrower credit risk objectively and fairly, without the influence of subjective human judgment or biases. In turn, the FICO Score transformed those markets in fundamental ways that benefit consumers, lenders and investors, and our success has been hard-earned through continued product innovation and a commitment to safety and soundness, and not as the result of any government action or anticompetitive practices.
History of the FICO Score’s Adoption
FICO released the first generally available FICO Score to U.S. consumer credit markets in 1989. The FICO Score soon became widely used by lenders in making credit decisions on mortgages and other types of consumer credit. In 1991, the FICO Score became available at all three major consumer reporting agencies, Experian, Equifax, and TransUnion (the “CRAs”). In 1995, Fannie Mae and Freddie Mac—when they were operating as for-profit corporations owned by private shareholders—voluntarily adopted the FICO Score in the conforming mortgage market because it was the score that lenders were already widely using as the industry standard measure to evaluate consumer credit risk when making credit decisions for their own portfolios (inside and outside the mortgage market). Driven by FICO’s continued innovation and the substantial value provided, the FICO Score has remained the trusted and consistent measure of credit risk in the conforming mortgage market ever since, both in the 13 years before Fannie Mae and Freddie Mac were placed into governmental conservatorship in 2008 and in the 16 years since the conservatorship was established.
Notably, however, the vast majority, approximately 99%, of FICO Scores used for decisioning across the consumer credit industry are used outside mortgage originations. In fact, even within the mortgage market, lenders originate nearly 30% of all mortgages outside the Fannie Mae and Freddie Mac programs but still choose to use FICO Scores for those mortgages. In sum, adoption of the FICO Score by Fannie Mae and Freddie Mac in the conforming market, and by thousands of market participants outside that market, is the direct result of the value the FICO Score provides and not the result of any government action or anticompetitive practices.
FICO’s Royalty Rates Have Been Historically Underpriced
Despite the value the FICO Score provides, it is important to note that FICO has neither the access to the necessary credit data nor the means of distribution to provide Scores directly to end users (e.g., lenders). Instead, FICO licenses its proprietary credit scoring models to the three CRAs. Accordingly, it is ultimately the CRA—not FICO—that sets the price the resellers and end users pay for the FICO Score.
With respect to the royalties FICO charges the CRAs, those royalties have historically been priced substantially below the value derived from our scores by other market participants. This underpricing situation arose because the wholesale royalties for FICO Scores used in mortgage were originally established in 1989 and remained at those low amounts for decades due to contractual and technical constraints. As a result, the royalty rates that FICO received from each of the CRAs were essentially flat for nearly 30 years after the FICO Score was introduced in 1989.
In 2012, FICO began the process of re-negotiating its license agreements with each CRA, which took several years. The agreements FICO and each CRA eventually reached finally gave FICO the right to adjust its base royalty rates for FICO Scores once per year, with advance notice to the CRAs. As a result, FICO first adjusted its royalty for mortgage in 2018, but unlike in other markets where FICO had adopted a volume-based tiered royalty pricing structure (e.g., auto loans, credit cards and personal loans), certain technical and structural constraints in the mortgage market required FICO to continue to charge a flat royalty in the mortgage market regardless of volume or other factors: approximately 50-60 cents per score for all mortgage lenders starting in 2018.
By September 1, 2022, well before the Federal Housing Finance Agency announced the validation and approval of FICO Score 10T in the conforming market, FICO notified the CRAs that, consistent with other markets, it was adopting a tier-based royalty structure for mortgage, generally based on the volume of FICO Scores delivered to lenders. Under that tiered structure, FICO’s royalty for the highest volume tier remained unchanged, and the royalty for lower-volume tiers increased, although that was only the second increase in FICO’s nearly 30-year history of providing credit scores to the mortgage market, apart from customary adjustments to account for inflation over the last few years.
With that change, FICO began collecting in 2023 approximately $0.60 to $2.75 per FICO Score, which equates to approximately $2-$8 total for all three scores out of a $40 to $70 (or more) tri-merge report and score bundle. Notably, with that change, all amounts for the tri-merge report and score bundle above that $2-$8 were collected and retained by others who sell and distribute the scores.
FICO’s New Mortgage Royalty Structure
After announcing our adoption of the tier-based royalty structure for 2023, various market participants provided valuable feedback, raising potential concerns and challenges presented by implementing such a structure, and urging FICO to reconsider the tier-based approach. After careful evaluation of the feedback, we decided to eliminate the tier-based structure. With our new wholesale pricing structure for 2024, we eliminated the tiering so that the same per-score wholesale price applies for mortgage lenders: approximately $3.50 per FICO Score used in mortgage originations. All amounts above this FICO Score wholesale price per score, charged as part of a tri-merge score and report bundle, are collected and retained by others.
It is important to note, though, that even after this current adjustment, at $3.50 per FICO Score, the royalty collected by FICO in the mortgage market constitutes only 15% of the cost of a $70 tri-merge credit report, the substantial value of which is derived from the FICO Score itself. With average closing costs of approximately $6,000 per mortgage[1], FICO’s royalties remain an exceedingly small percentage—approximately two tenths of one percent (or less)—of a consumer’s closing costs and are therefore not an impediment to home ownership. Additionally, we believe the cost of the FICO Score relative to its value is entirely fair and reasonable particularly when all further downstream uses by industry participants are considered. Beyond its initial use in originations, the FICO Score is then transmitted and leveraged throughout the mortgage credit ecosystem—from underwriting, mortgage insurance, pricing and delivery, and securitization to rating by credit rating agencies, evaluations by broker/dealer desks, credit risk transfer, servicing, risk management, investor disclosure, and regulatory and capital requirements, in each case at no incremental royalty charged by FICO beyond the per score amount collected for the initial origination use itself.
The confidence, stability and efficiency the FICO Score affords mortgage market participants supports market liquidity, which in turn expands credit availability and lowers overall mortgage costs to households. The FICO Score’s adoption is a testament to the market’s recognition of its tremendous value and the central role it plays across U.S. consumer credit markets. FICO continues to drive innovation with its newest most predictive FICO Score version, FICO Score 10T. Several large mortgage lenders and servicers have recently announced joining FICO’s early adopter program designed to support transition to FICO Score 10T for use in mortgage outside of the conforming market.
Learn More About FICO Scores for Mortgage Lending
- Learn about FICO® Score 10T, the independent, most predictive credit score on the market and get in touch to learn how you can join other mortgage lenders now expanding homeownership opportunities and reducing risks
- Download the FICO® Score 10T model assessment whitepaper to understand how new credit scoring models could help more consumers qualify for mortgages
- Watch the interview with Primis, where they share how leveraging FICO® Score 10T opens doors for borrowers who were previously "fit into a small box."
[1] See Data Point: 2022 Mortgage Market Activity and Trends (September 2023), https://files.consumerfinance.gov/f/documents/cfpb_data-point-mortgage-market-activity-trends_report_2023-09.pdf.
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<p>FICO’s latest research on <a href="http://www.fico.com/en/blogs/risk-compliance/us-credit-quality-rising-the-beat-goes-on/" target="_blank">national FICO® Score distribution</a> shows that US credit quality continues to trend upwards, with an increasing number of consumers scoring in the highest scores ranges. Given that, we decided it was time to refresh our study on “<a href="http://www.fico.com/en/blogs/risk-compliance/infographic-what-does-a-high-credit-scorer-look-like/" target="_blank">FICO® Score high achievers</a>,” where we examine the credit behavioural profiles of consumers with higher credit scores.</p> <p>As expected, our latest study showed that older people generally have higher scores, as has been the case in our <a href="http://www.fico.com/en/blogs/risk-compliance/age-before-beauty-credit-worthiness-before-youth/" target="_blank">past research</a>. 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I further broke this down by looking at the characteristics of the youngest 15% in each group, which occurs at age 29 for the 750-799 group and 43 for the 800-850. We used FICO<strong>®</strong> Score 9 for our analysis, and examined typical variables of the categories that go into the make-up of the score.</p> <p><a href="http://www.fico.com/en/blogs/wp-content/uploads/2016/10/FICO-Score-High-Achiever-table.png"><img class="alignnone size-full wp-image-29367" src="http://www.fico.com/en/blogs/wp-content/uploads/2016/10/FICO-Score-High-Achiever-table.png" alt="fico-score-high-achiever-table" width="715" height="747" /></a></p> <p>Since there’s a lot to dissect in this chart, I’ll highlight a few findings that struck me: <ul> <li><strong>Credit history.</strong> Higher scores are undoubtedly associated with a longer time on file. What’s striking is the higher average time on file for the 800+ group, both overall and for revolving accounts (the most common trade line). Clearly, it helps to start credit use early in life – but that’s not the sole determining factor for high scoring. The younger cohorts in both the 800+ and 750-799 groups have time on file medians significantly less than their older counterparts.</li> <li><strong>New credit.</strong> High credit scorers do, in fact, pursue new credit. We see little variation in months since last trade line opening and last inquiry among all groups observed.</li> <li><strong>Pay on time.</strong> As you might expect, the further in the past the delinquency, the higher the score – and that’s <u>if</u> a delinquency ever happened. 95% of the 800+ people and 72% of the 750-799 group have never been delinquent, which is a striking contrast to the 57% for the total population. The percentages for the younger groups are even higher, especially so for the 750-799ers. Collection items are also scarce for these high scorers. While 23% of the national population have collection items greater than $99, the figures are only 0.5% for the 800+ group and 3% for the 750-799 group. It is clear that, in conjunction with starting a credit file early, paying on time is a key trait of the FICO® Score high achiever.</li> <li><strong>Balance and utilization.</strong> Finally, we look at how credit is being used, focusing on revolving product use. (Since most people only have one mortgage or one auto loan, variation in instalment product figures is minimal and driven by payment history, which is near perfect for high scorers, as we’ve seen.) FICO® Score high achievers tend to have more open revolving accounts. While the % active trades and utilization are generally lower, by no means do high scorers avoid the use of credit products. What drives the difference here is the amount of <u>available</u> revolving credit utilized. 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A huge takeaway is that high scorers don’t have too much in the way of serious delinquencies and negative public record data.</p> <p>In most respects, the young 800+ people are like their peer group. They really only differ markedly in their shorter credit history and higher non-mortgage balance, both of which are a function of life stage. Our results show that you don’t have to be a credit product hermit; these high scorers have more credit cards. The takeaway is to start credit activity early and maintain well-managed and moderate usage.</p> <p>In many ways, the young 750-799 people are more interesting because their age profile is much younger. Their credit characteristics differ more from their peer group, particularly in terms of length of credit history. They compensate by having almost pristine credit records and lower balances.</p> <p>Ultimately, 39% of US consumers are FICO® Score high achievers, which they accomplish by following common-sense credit practices. 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