Case studies · No. 0129 Sep 2026 · NYSE: FICO
When a moat is written by a regulator

The rule
was the moat

FICO lost more than half its value in two months. Its scores didn't get worse and its revenue kept growing. What changed was the rule that forced lenders selling loans to Fannie Mae and Freddie Mac to buy them. This is how that happened, what could come next, and the seven checks I now run so I don't get caught by the same pattern.

$1,373Close, 29 Jul 2026
$618Close, 29 Sep 2026 (−26.5% on the day)
−55%In about two months
3Single-day drops of 15% or more
The fall

Three hits, one story

FICO daily close, USD29 Jul – 29 Sep 2026 · last point = 29 Sep close

Source: IBKR daily bars. 29 Sep close $617.87, intraday low $595.19.

  1. FICO announces its Mortgage Direct License Program. It would let resellers deliver FICO scores without going through the credit bureaus. Classic scores would cost $4.95 each, plus a $33 fee "per borrower per score" when the loan closes. As of late July 2026 it was still waiting on certification from Fannie or Freddie to go live.
  2. The regulator starts a pilot. FHFA lets the 21 largest lenders deliver loans to Fannie Mae and Freddie Mac scored only with VantageScore 4.0, the bureaus' own score.
  3. Strong quarter, weak details. Results came out after the close on 29 Jul. Revenue grew 26%, but mortgage volumes grew only in the low single digits, management said it was "literally waiting on certification" before the licensing program could go live, and TIKR described VantageScore as "gaining some traction". −17%
  4. VantageScore opened to every lender. Fannie and Freddie must accept it from all approved lenders, not just the pilot group. −17%
  5. One pricing grid. FHFA says Fannie and Freddie will merge their loan-pricing tables into one grid that includes VantageScore alongside Classic FICO. No start date or new pricing table published yet. −26.5% on 29 Sep
The mechanism

Why a $0.99 rival is a big deal

For years, loans sold to Fannie Mae and Freddie Mac had to carry a Classic FICO score. Lenders had no choice, so FICO could raise its mortgage price again and again. Reports on the latest quarter note that mortgage growth came from price, not from more loans.

If one pricing table treats both scores alike, a lender who picks VantageScore gets the same loan pricing for a fraction of the score cost. The chart below shows what that gap looks like on a single mortgage application.

Score cost for one borrower whose loan closesIllustration · 3 scores (one per bureau) · list prices · closing fee counted once

Traditional model: $10 per score. Performance model: $4.95 per score plus a closing fee FICO describes as $33 "per borrower per score". FICO 10T: $0.99 per score plus a $65 closing fee. This chart counts each closing fee once; if it applies to all three scores, the performance model is $113.85 and 10T is $197.97. VantageScore 4.0: $0.99 per score, and TransUnion includes it at no extra charge through 2026 for mortgage customers who also buy a FICO score. Resellers add their own fees on top. FICO's direct-license prices were not yet live as of July 2026.

TransUnion mortgage pulls that include VantageScore

These are pulls that include VantageScore, not loans underwritten with it. TransUnion bundles it free with a FICO purchase, so many are likely lenders taking both scores. The direction is still clear.

What investors pay per $1 of earnings
50x+
2023–25
~24x
Mar 2026
~15x
Now

Scale runs 0x to 60x. "2023–25" is trailing GAAP P/E, which ran above 50x each year and hit 93x in Sep 2024 (FullRatio). "Mar 2026" is the forward multiple cited by Investing.com. "Now" is the $617.87 close against FICO's FY26 guidance of $42.43 non-GAAP EPS; on the $36.86 GAAP guidance it is about 17x. On 29 Jul, before the fall, the same measure was about 32x. When a premium multiple meets a threat to pricing power, both the earnings and the multiple fall together.

What happens next

Three futures for FICO

Almost everything depends on one line of the income statement. Last quarter, mortgage origination scores brought in $283M, 71% of score sales to lenders and about 42% of all revenue. They cost almost nothing to produce, so they carry most of the profit.

Where FICO's earnings per share come fromEstimate · Q3 FY26 run-rate, annualised

My own estimate, not company guidance. It assumes mortgage scores earn about a 90% margin, and applies the company's 62% non-GAAP operating margin, $5.6B of debt at 5.64% interest, and a ~24% tax rate, and charges all interest expense to the rest of the business. Sharing interest in proportion to operating profit instead would give roughly $30 from mortgage scores and $19 from the rest. The rest covers auto, card and consumer scores plus software.

Rough share price in 2–3 years, by scenarioUSD per share · ranges, not targets
Worst · 25%
$250–300
~$18 EPS × ~14x
  • Lenders shop for whichever score gets the cheapest loan pricing, and FICO keeps only ~35% of the volume Fannie and Freddie buy.
  • The bureaus bundle VantageScore free, so FICO cuts its price per loan by ~70% to stay in.
  • Net debt of 3.7x EBITDA leaves no room for buybacks. Other agencies follow FHFA.
Base · 50%
$500–600
~$27 EPS × ~20x
  • A slow loss of share: FICO keeps ~60% of that volume.
  • FICO accepts a price per loan ~45% lower to get its newer 10T score approved.
  • It stays the leader, but mortgage becomes a normal business. The stock trades like a quality company, not a 50x one.
Best · 25%
$900–1,000
~$39 EPS × ~25x
  • Mortgage-bond investors keep wanting a FICO score on every loan, so lenders keep pulling FICO and it keeps ~80% of that volume.
  • FHFA's own mid-September pricing grids, which TD Cowen reads as showing VantageScore overstates credit quality by about 20 points versus FICO, slow the new grid. 10T is approved at a fair price.
  • Rate cuts lift mortgage volume. Platform software (+62% recurring revenue) becomes a second engine. A future regulator could even reverse the rule.

What will tell us which path FICO is on

  1. FY Q4 earnings and FY27 guidance. The mortgage revenue guide is the single most useful number.
  2. FICO 10T cleared for Fannie and Freddie, and at what price. Approval at a price close to today's points toward the best case. A deep cut points toward base.
  3. A start date for the single pricing grid, and whether lenders may use two bureau reports instead of three.
  4. VantageScore share at Equifax and Experian, not only TransUnion. A rise at all three signals the worst case.

My read. Weighting the three cases 25 / 50 / 25 (EPS × multiple in each) gives about $577, a little below its $617.87 close on 29 Sep. The market isn't obviously wrong, and there is no margin of safety yet. FICO also shows red on five of the six company checks in the stress test below, so I'm watching, not buying, until the November guidance.

Scorecard. I don't own FICO. After the FY Q4 report in early November I'll come back to this page and score these scenarios against what actually happened.

Takeaways

Seven lessons I keep

  1. Ask who grants the moat.

    A moat that comes from a rule can be taken away by a rule. Before paying up, ask: if the rule disappeared tomorrow, would customers still choose this product?

    FICO passes in credit cards and auto loans, where lenders choose it freely. In mortgages, where a rule did the choosing, that is still unproven.

  2. Growth from price has a political ceiling.

    Check how much growth comes from raising prices versus selling more. If those price increases land on a bill voters already complain about, expect someone in government to notice.

    Mortgage score prices rose sharply during a national argument about housing affordability. FHFA Director Bill Pulte then criticised FICO's pricing in public, saying FICO "had taken their prices from $4.95 up to $10".

  3. Watch when your distributor owns your rival.

    If the companies that sell your product also own a competing one, they can switch their effort the moment the rules allow it.

    The three credit bureaus sell FICO scores and co-own VantageScore. TransUnion added VantageScore free for mortgage customers buying a FICO score, and the share of its mortgage pulls that include VantageScore went from under 5% at the start of 2026 to about 30% in Q2.

  4. A premium multiple doubles the fall.

    At 40–50x earnings, a stock is priced for years of unchallenged pricing power. When that is questioned, earnings estimates and the multiple drop at the same time.

    Trailing P/E was above 50x in 2023–25. It is now about 15x on this year's guidance, while revenue was still growing 26%.

  5. Cheap versus its own history is not a floor.

    Historical multiples describe the old business. Once the business model changes, "lowest in ten years" says little about where the bottom is.

    In March 2026, about 24x forward earnings was called a 10-year low, with an average target near $2,068 and the stock around $1,100. It has since fallen about another 44%.

  6. A thesis-breaking gap means exit, not add.

    A big one-day drop caused by the market is noise. A big drop caused by news that breaks the thesis is information. Reduce or exit, and buy back only on new evidence.

    The 4 Sep and 29 Sep drops were each the regulator taking another step in the same direction. Anyone averaging down after one step took a bigger loss on the next.

  7. Debt-funded buybacks at the top turn a setback into a squeeze.

    A company that borrows to buy back its own stock at a premium price is betting that nothing changes. If the business then weakens, the debt stays while the shares it bought are worth half.

    In the June quarter FICO spent $1.96B buying its own stock at an average $1,149, partly with a new $1.5B loan. Debt is now $5.6B, net debt is 3.7x EBITDA, and the stock is at $618.

The check

Moat stress test

Run this before adding any "wide moat" name, and again when a position gaps down 15% or more on company news.

#QuestionFICO mortgage, as of 29 Jul
01Would customers still choose it if no rule required it?Unproven
02Is most recent growth from price rather than volume, on a politically visible bill?Yes
03Does a distributor or partner own a competing product?Yes
04Is the multiple well above the market (35x+)?Borderline, 32–37x
05Has a regulator or politician named the company's pricing in public?Yes
06Is there a written exit rule for a thesis-breaking gap?Investor check
07Is management borrowing to buy back stock at a premium multiple?Yes

Row 04 uses FY26 guidance at the 29 Jul close: about 32x non-GAAP, 37x GAAP. Row 06 is about you, not the company. Two or more red answers: size smaller, write the exit rule before buying, and track the regulator's calendar as closely as the earnings calendar.

Beyond FICO

Where this pattern could show up

Payment networks (MA, V)

The moat is mostly the network itself, which passes check 01. But card fees are a political target, so checks 02 and 05 deserve a look before paying up for them.

Mostly passes

AI power producers

Rising electricity bills tied to data-center demand are becoming a political issue, and grid operators have capped capacity-auction prices before. That is check 02: growth from price on a bill voters see.

Watch closely

The best moats survive a rule change. Own the ones customers would choose anyway.

Corrections

29 Sep 2026, after first publication: close updated to IBKR's final bar ($617.87, −26.5%); Direct License Program described as announced, not live; the $33 fee quoted in FICO's own words; TransUnion's free offer limited to FICO buyers; the VantageScore figure described as pulls that include it; leverage described as net debt to EBITDA; the ~20-point finding and the MBS point attributed to TD Cowen; the 30 Jul drop no longer attributed to the regulator; stress-test rows 01, 04 and 06 corrected; multiples given with their basis and sources. The scenarios, odds and price ranges are unchanged.

Sources