The FHFA cleared VantageScore 4.0 for agency mortgages a year ago and says a FICO 10T deal is near. Every credit box calibrated to classic FICO cutoffs is drifting underneath its owner.

_{Sources
1 Asset Securitization Report | With Updated FICO Model, Figure Lending Floats $321.1 Million on HELOCs
2 National Mortgage News | With Updated FICO Model, Figure Lending Floats $321.1 Million on HELOCs
3 FHFA | Validation of FICO 10T and VantageScore 4.0 for Use by Fannie Mae and Freddie Mac
4 ABA Banking Journal | FHFA Nearing Deal to Use New FICO Credit Scoring Model for Mortgages
5 Inside Mortgage Finance | HEL Securitization More Than Doubles in 3Q
6 Home Equity Lending News | Biggest HELOC Lenders
7 Sixth Street | Figure Technology Solutions and Sixth Street Form Joint Venture
8 Business Wire | Figure Technology Solutions Announces Pricing of Initial Public Offering
9 ClassAction.org | Figure Lending Facing Class Action Lawsuit Over February 2026 Data Breach
10 US District Court (W.D.N.C.) | Mardikian v. Figure Lending LLC, No. 3:26-cv-00135, Class Action Complaint
11 BleepingComputer | Data Breach at Fintech Firm Figure Affects Nearly 1 Million Accounts
12 US News | West Capital Lending Mortgage Review
13 SEC EDGAR | Oportun Financial Form 8-K, Program Management Agreement With Column N.A.
14 Forbes | Plaid's Co-Founder Is Back With a Fintech-Friendly Bank
15 Yahoo Finance | Pathward, Oportun Extend Lending Partnership
16 Congress.gov | H.R. 9330, Earned Wage Access Consumer Protection Act
17 Consumer Finance Monitor | House Financial Services Committee Advances Federal Earned Wage Access Bill
18 American Banker | A Complete Guide to Earned Wage Access Regulation by State
19 American Banker | Axos to Buy San Francisco Fintech and Its AI Technology
20 Axos Financial | Axos Financial, Inc. to Acquire Arc Technologies, Inc.
21 Finovate | Arc Technologies Venture Debt Lending Platform Reaches $100 Billion in Committed Capital
22 Payments Dive | Capital One to Acquire Brex in $5 Billion Fintech Deal
23 FICO | FICO Score 9 Introduces Refined Analysis of Medical Collections}

The deal itself is unremarkable by 2026 standards: 4,905 lines, draw periods of three, four, or five years, average seasoning around three months with a one-to-eight-month range, final maturity June 2056, Figure servicing with Northpointe Bank as backup.^{1 2} What is new is that the credit scores stamped on the collateral tape come from FICO 9, and the rating agency treated that as an underwriting fact to be rated, not an experiment to be discounted. Class A still carries a provisional AAA.¹

The difference between the models is not cosmetic. A borrower with a repaid collection account, a medical bill that went to collections, or a documented rent history is a different number on FICO 9 than on the classic model.¹ Aggregate enough of those borrowers into one pool and the pool's stated score distribution shifts without a single underwriting decision changing. That is the mechanism to hold onto, because it works in both directions: it can genuinely reveal creditworthy borrowers the old model punished, or it can relabel the same risk at a higher number. Which one happened here is not answerable from the outside, and the reason why is a section of its own below.

Figure originated 44.2% of the pool. West Capital Lending contributed 29.1%, and every other originator sits under 10%.¹ FIGRE is a marketplace pool aggregated through Figure's platform, and the platform's name on the shelf is doing the reputational work for underwriting done by companies most investors have never diligenced.

That structure is not a criticism of Figure; it is the announced direction of its business. Figure Lending originated 30,052 HELOCs for $2.41 billion in 2024, ranking fourth among all US HELOC lenders with the banks included.⁶ A February 2025 joint venture with Sixth Street committed $200 million of recyclable equity to keep an always-on bid under Figure paper and forward-sell the bonds.⁷ The machine is built to aggregate and issue. For anyone in this audience who buys participations, syndications, or forward flow in commercial paper, the transferable discipline is the same one FIGRE buyers face: diligence the originator on the tape, not the logo on the term sheet. A pool is only as consistent as its least consistent contributor.

If FICO 9 collateral feels like a private-market experiment, the agency channel is further along. On July 8, 2025, the FHFA announced that lenders may use VantageScore 4.0 for loans delivered to Fannie Mae and Freddie Mac, alongside classic FICO.³ Director Bill Pulte has since said the agency is nearing a deal to add FICO 10T.⁴ The one-model monoculture that let every lender, vendor, and investor assume a 700 meant the same thing everywhere is being dismantled on purpose, by the regulator that anchors the largest credit market in the country.

The volume backdrop says this is not a niche corner. Securitization of HELOCs and closed-end seconds ran more than 70% ahead of the prior year through nine months of 2025, per Inside Mortgage Finance.⁵ New scoring models are not being tested on the fringe; they are being embedded in one of the fastest-growing collateral classes in structured finance.

Here is the honest gap: the publicly reported deal facts include no weighted-average FICO, no weighted-average CLTV, no coupons, and no spreads. Without the weighted-average score and loan-to-value, nobody outside the deal can tell whether FICO 9 expanded Figure's credit box or simply relabeled the same borrowers at new numbers. Without pricing, the deal offers no cost-of-capital benchmark. That silence is itself information: issuance is running on a scoring model the buy side cannot fully cross-examine from public documents, and the paper cleared at AAA anyway. When the market accepts a model swap without demanding the comparison metrics, the swap becomes normal by default. Treat any future claim that FICO 9 pools "perform the same" with the same skepticism until someone publishes the distributions.

Two facts frame the issuer. Figure Technology Solutions went public in September 2025, pricing 31.5 million Class A shares at $25 on Nasdaq under FIGR, an upsized offering worth roughly $787.5 million in gross proceeds.⁸ It also suffered a February 2026 data breach affecting roughly 967,200 accounts, which a spokesperson described to TechCrunch as a social engineering attack, and it faces a proposed class action, Mardikian v. Figure Lending, No. 3:26-cv-00135 (W.D.N.C.), whose unproven allegations concern data safeguards, not the credit performance of this collateral.^{9 10 11}

Find out which score version actually feeds your decisioning. Ask your bureau reseller and every data vendor in your underwriting stack one question: which FICO model version, or which VantageScore version, is returned under your current contract? Most alt-lenders inherited the answer years ago and have not looked since. If your vendor migrates versions mid-contract, your cutoffs move with it whether you noticed or not.

Check which score version your credit facilities reference. Warehouse lines, forward-flow agreements, and participation deals routinely embed minimum guarantor-score eligibility criteria that were written when one model was the only model. If your facility documents say 660 and your bureau migrates versions, your covenant compliance and your eligible-collateral base move without a single loan changing. Ask your capital providers which score version their eligibility criteria assume, and get it in writing before an audit asks first.

Re-baseline the cutoff against the population, not the number. Pull your last batch of approvals and declines that landed within 20 points of your guarantor-score cutoff and rescore them under the newer model your vendor offers. The size of the reshuffle tells you whether your 650 still selects the population your loss curves were built on. FICO's own release put the median score gain at 25 points for consumers whose only major negatives are medical collections, which is exactly the marginal-file population that clusters at cutoffs.²³

If you buy pooled paper, demand originator-level tapes. A platform-branded pool is six underwriting shops wearing one jacket, and buyers should price the dispersion between contributors, not the average of the pool.

A borrower can report one advance while public UCC records show multiple secured parties. Cobalt surfaces UCC filing data so the underwriting team can review the public record before making the decision.

Read more: How UCC Data Reveals Loan Stacking in MCA Portfolios

Two days after Klarna filed to own a bank, Oportun signed a four-year Program Management Agreement to rent one. Under the June 30 agreement, disclosed in a July 7 SEC filing, Column National Association, the San Francisco chartered bank built by Plaid co-founder William Hockey, originates unsecured personal loans in select states while Oportun runs marketing, fraud prevention, and servicing under Column's oversight, with an option to purchase every loan Column does not retain.^{13 14} The exclusivity carve-out for existing bank partner rights points at Oportun's standing Pathward relationship, and the real economics, reserves, and wind-down terms arrive with the 10-Q exhibit.¹⁵ For anyone weighing a bank-partner channel against state licensing, this is the current market template: originate-then-purchase, four years, auto-renewing.

The House Financial Services Committee cleared H.R. 9330, the Earned Wage Access Consumer Protection Act, on July 1 by a 31-23 party-line vote.^{16 17} The bill defines earned wage access as non-credit and outside the Truth in Lending Act, mandates a free-advance option, and would preempt state laws that classify EWA as credit, aimed squarely at California's loan-classification regime while leaving most state registration frameworks standing.^{17 18} With no Senate companion, near-term enactment is unlikely. The reason it belongs on a commercial desk's radar anyway: it is a federal statute declaring a non-loan advance product to be non-credit and overriding contrary state classification, which is the same legal architecture MCA and revenue-based financing operators argue about every day.

Axos Financial, a $29.2 billion-asset digital bank, agreed July 6 to buy Arc Technologies, whose marketplace routes startup borrowers to roughly 100 third-party lenders and reports over $100 billion in committed capital; the price was not disclosed and the deal is expected to close this month.^{19 20 21} It is the second AI-native SMB-finance platform absorbed by a deposit-funded bank in three months, after Capital One closed its $5.15 billion Brex purchase in April.²² The open question for the independent lenders sourcing deals through Arc is whether Axos internalizes origination onto its own balance sheet; whether forward-flow commitments transferred with the platform has not been disclosed. If Arc is in your sourcing stack, open a second channel before the answer arrives.