X-Ray Analyses›Technology›Fair Isaac
X-RayNº 944 November 2026
X-Ray Analysis◆The Buffett Lens
F

Fair Isaac

NYSE: FICO·Software - Application·United States·Explore FICO live ↗

The toll that became a negotiation

◆ The Buffett LensFor thirty years almost every American mortgage ran on a number that one small company sold. FICO spent the last eight of them raising the price from about 60 cents to $10. Then the regulator let lenders use a rival at 99 cents and put both on one pricing grid, and four bad days took more than half of the stock's value. Tonight's results were good, the antitrust case may close for just $65m, and yet FICO declined to give a guide for 2027. We ask what survives of the toll, what the borrowed buyback did to the balance sheet, and whether a 62% fall has made this cheap.
◆ Educational analysis & opinion — not investment advice. Figures as of 4 November 2026. See full disclaimer below.
6
Moat
5
Management & Capital
4
Financial Strength
5
Growth
5
Valuation
5.2
◆ The Scorecard · one-second read
"A 62% fall does not make a stock cheap. It makes it cheaper than it was. At this price you are paying a full sum for a toll whose owner can no longer say what it will charge next year."
Revenue +27% · Scores margin ~91% · No fiscal 2027 guide · Vantage in 37% of DU applications, 6% of Fannie deliveries · Net debt ~3.7× EBITDA · ~17.5× owner earnings of ~$40
◆ Type · A government-conferred toll, now a commercial standard that must defend itselfDividend · None since 2017 — all returns through buybacksRisk · FHFA policy, VantageScore, debt of $5.26bn against negative equity
The price journey
Daily closes · the gold dot marks the price when we published this analysis
Live price history is momentarily unavailable. Range at analysis: 4 November close, before the fiscal Q4 results · 62% below the 52-week high of $1,858.91 · 71% below the record close of $2,382.40 · 52-week low $586.05 · ~16× non-GAAP EPS of $42.99 · ~17.5× owner earnings · no dividend since 2017.
Every number above comes from the live FICO page: interactive chart, 15 years of financials, DCF & peers. The account is free. No card.Create free account →
◆
Part
I

The business, in plain English

Three digits that decide what you pay for a house, sold by a company that owns none of the data behind them

Fair Isaac makes the FICO score, the three-digit number between 300 and 850 that American lenders use to judge whether you will pay them back. A ten-year-old could follow the idea. Three credit bureaus, Equifax, Experian and TransUnion, keep a file on nearly every adult: what you owe, whom you owe it to, whether you paid on time. FICO wrote the recipe that turns a file into a number. It owns the recipe and none of the ingredients. Each time a lender asks for a score, a small fee flows back to FICO.

That fee was tiny for a very long time, and the cost of running the recipe once more is close to nothing. So the Scores business earns a margin of about 91%. Scores brought in $1.65bn of the $2.53bn of revenue in the fiscal year to 30 September 2026, about 65%, and on the last segment figures we have, in the June quarter, it made nearly 90% of segment profit. Within Scores, the money that matters is a single line: mortgage originations. That one line was about 42% of company revenue in the June quarter and about 37% in September.

The rest of the company is Software: decision and fraud tools for banks, sold under the FICO Platform name. It had revenue of $883m last year at a margin in the mid-20s. It is a respectable business that nobody bought the stock for, and it now matters more than it ever has.

The whole enterprise needs very little capital: $38m of capital spending last year, 1.5% of revenue. It has turned that fact into a remarkable financial structure. It has spent roughly $9.5bn on its own shares since 2012, has cut the share count by about two-fifths, and today has $5.26bn of debt and negative book equity of $3.87bn.

Total return, twenty years to Nov 2026
~18×
About 15.4% a year, against 10.9% for the S&P 500 (SPY)
The last ten years
+488%
19.4% a year: ahead of the S&P 500's +307% (15.1%)
The last year
−59%
Against +13% for the S&P 500

Add one more cell in your head. Over five years, FICO has returned +62% against +80% for the index. A shareholder who bought in late 2021 has spent five years, through the greatest price increase in the company's history, to finish behind a fund that charges almost nothing. At its record close of $2,382.40 on 26 November 2024 the stock was worth about 66 times what it fetched when Will Lansing became CEO in January 2012. It is now worth about 19 times. That is still a wonderful result, and it tells you how far the price had run ahead of everything else.

◆
Part
II

The history — a letter gave it and a post took it away

Seventy years from a rejected pitch to a monopoly, and eighteen months from a monopoly to a negotiation

WhenWhat happenedWhy it matters now
1956 – 1958Bill Fair and Earl Isaac, who met at Stanford Research Institute, form a 50-50 venture. They pitch credit scoring to 50 banks and finance companies; one responds.Credit managers thought lending was about judging character. The idea took decades to win.
1987IPO in July on about $18m of sales. The stock falls 64% within months, in the crash.It had fallen by more than 45% five times before this one. Each time it recovered.
1989 – 1991The general-purpose FICO score arrives. By 1991 it is at all three bureaus.The design decision that haunts it: FICO built the recipe, and <b>the bureaus kept the data and the distribution</b>.
1995Freddie Mac tells lenders to use it. The sociologist Barbara Kiviat writes that the letter caught Fair Isaac off guard. Fannie Mae follows.The moat was handed over by an agency of the government. FICO did not ask for it, and could not keep it by itself.
2006 – 2011The three bureaus launch VantageScore. FICO sues them. A jury finds the 300–850 range merely descriptive, and it loses on appeal in 2011.Its three biggest customers have owned its main competitor for twenty years.
2012 – 2015Will Lansing, a director since 2006, becomes CEO with the stock near $36, and spends three years rewriting the bureau contracts so that FICO can change its base price every year.The quiet act that made the fortune: mortgage royalties had been roughly flat for nearly 30 years.
2018 – 2025The ladder: about 60 cents, then $3.50 in 2024, then $4.95 in 2025. Record close $2,382.40 on 26 November 2024.The market capitalised this as a price rise for ever. The five-year average forward P/E was about 40×.
May 2025 – Oct 2025Bill Pulte, head of the FHFA, starts posting about FICO's costs. In July he lets lenders use VantageScore 4.0. On 1 October FICO launches a direct licence that cuts the bureaus out: the stock rises 18%.It declared war on its own distributors. They answered within weeks.
2026The $10 wholesale price takes effect; the bureaus cut Vantage to about $1 in March. All lenders are approved in September and one pricing grid follows on 1 October. Rocket makes Vantage its default on eligible loans. Three falls take the stock to a closing low of $592.47 on 30 September, and a fourth follows in October.No statute changed. A conservator changed the rules for two companies it controls, and that was enough.
4 Nov 2026Fiscal Q4: revenue +27%, a $65m proposed antitrust settlement, and no guidance for fiscal 2027.The subject of Part V.

The neatest summary of this history is that the franchise began with a letter from Freddie Mac and was opened up by posts from Freddie Mac's conservator, and that FICO's consent was required for neither. Everything impressive that Lansing did sits between those two events. He saw that a product worth a great deal to lenders was being sold for almost nothing, and he had the patience to rewrite the contracts. He also never built a defence against the one party that could change the rules, and it is hard to say what that defence would have been. The company's own 10-K has long named the risk: if other credit score models are approved, it could have a material adverse effect on revenue and on the stock. Few people read that sentence until 2025.

◆
Part
III

Inside the circle of competence?

The product takes a paragraph to explain. The price of it now depends on one regulator, three rivals and a few hundred lenders

We can explain how FICO makes money in a paragraph, which is the first test. The second test, whether we can say what it will look like in ten years, is where the trouble starts. Until 2025 this was the sort of business you could leave alone for a decade. Today the forecast depends on what a political appointee does next, on how three companies that are both customers and competitors choose to price, and on private contracts between FICO and individual lenders whose terms are not public. Those are hard things to know from the outside.

How a mortgage score gets paid for
1
The borrower
Applies for a mortgage. The credit-report cost goes on the closing statement, or stays with the lender if the loan does not close.
→
2
The lender
Orders a tri-merge report, usually twice per loan. It may now also pull VantageScore, which comes free with FICO from the bureaus.
→
3
The reseller
Bundles three bureau files and three scores. Under the direct licence the reseller would calculate the score itself.
→
4
The bureaus
Sell the data, and take the FICO royalty for the score. They were 63% of FICO's revenue in the June quarter.
→
5
FICO
Is paid per score pulled, whether or not that score prices the loan. That detail matters more than any other in this report.
How knowable is the next ten years?
2/5 — the need is certain; the price is not. Lenders will need a measure of credit risk in 2036. We cannot say what one mortgage score will cost in 2028, and tonight the company told us that it cannot say either.
What you must believe to own it at $701.03
  • That most lenders keep pulling FICO on every file, because the market still speaks in FICO: mortgage insurers, credit investors, manual underwriting, jumbo and FHA loans, and the habit of a whole industry.
  • That FICO keeps the $10 for several years against a rival at 99 cents, without a further rule change, and that mortgage revenue at least holds its level through a weak housing market.
  • That non-mortgage scores, which no regulator controls, keep rising, that Software compounds at about 9%, and that the debt comes down without a crisis.
◆
Part
IV

How the money is made

Where September's $657m came from, and what a price rise of about sixteen times did to the company

Mortgage originations36.5%
About $240m in the September quarter, up 72%: 58% of Scores revenue and 67% of business-to-business score revenue, on the CFO's figures. The whole argument is about this line.
Other B2B scores18.1%
Auto, cards, personal loans. About $119m. In the September quarter auto rose 11% and cards and personal loans 12%. No regulator stands in the chain.
Consumer (B2C)8.4%
About $55m, +3%. myFICO subscriptions and royalties on scores sold to consumers through the bureaus.
Software37.0%
$243.2m, +19%. Annual recurring revenue $851m, +14%. Platform $453m, +72%; non-platform $398m, −18%, which is at least partly customers moving across.
The price of a scoreMortgage score, per bureau, in dollars. The last step is the first without a rise.$0.60To 2022$3.502024$4.952025$10.002026$10.002027*$0.99Vantage★ * For lenders in the Preferred Program. The rival at a tenth of it is fixed to 2028.Not like for like: 60 cents was a royalty; $10 is wholesale, and the bureau mark-up moved to FICO.What the ladder did to the companyRevenue by segment, $ millions, fiscal years to 30 September.774740202392079820241,16982220251,6528832026ScoresSoftwareScores' margin is about 91%, so nearly all of the $878m added in three years reached profit.Sources: FICO 10-Ks, Q4 2026 release, Lansing blog (March 2024), HousingWire, TransUnion.

The ladder is not quite what the headlines say. Politicians quote a rise from 60 cents to $10, and it is a real rise, but 60 cents was a royalty paid by the bureaus and $10 is a wholesale price into resellers. FICO's defence is that $10 equals what the bureaus used to charge on average, since they marked up its product by about 100%, and that its own cost to a lender did not change. The revenue line settles the argument. In the June quarter, mortgage origination revenue rose 97% while volumes rose in the low single digits. FICO's take per score about doubled, and the mark-up moved from the bureaus to FICO. Both statements can be true: no increase to the lender, and twice the money to FICO.

You can see who paid in the bureaus' filings. TransUnion's US margin fell 230 basis points in its third quarter, which it put down mainly to FICO's royalties growing faster than revenue. Equifax's US mortgage revenue rose 15%, but 1% without the FICO pass-through. So the bureaus have been carrying a product that shrinks their margin, sold by a supplier trying to go around them. Anyone looking for the reason they are prepared to give VantageScore away should start there.

Is it expensive? It depends on what you hold it against. FICO says its contribution to a tri-merge bundle is at most $30, on a mortgage that costs thousands to close. In 2024 Lansing argued that royalties were about two-tenths of one per cent or less of closing costs. As economics, that is a sound argument. It stopped working when a rival arrived at one-tenth of the price, and when Senator Hawley and Mr Pulte decided that the size of the fee was less interesting than the size of the increase.

◆
Part
V

The quarter: good numbers, and a sentence that outweighs them

Filed at 21:15 UTC on 4 November, after the close. Our price is the close, so none of this is yet in it

Q4 FY26Q4 FY25ChangeFY26Change
Revenue$657.0m$515.8m+27%$2,534.9m+27%
Scores$413.8m$311.6m+33%$1,652.2m+41%
Software$243.2m$204.2m+19%$882.7m+7%
Operating income$266.6m$237.2m+12%$1,265.7m+37%
Net income$175.0m$155.0m+13%$835.0m+28%
EPS (GAAP)$8.12$6.42+26%$36.32+37%
EPS (non-GAAP)$11.10$7.74+43%$42.99+44%
Free cash flow$284.3m$210.8m+35%$1,034.4m+40%

Taken alone, these are fine results. Revenue came in slightly above the roughly $652m that the full-year guide implied, and non-GAAP EPS of $42.99 beat the $42.43 guide. Software revenue grew 19%, after 2% in June. Free cash flow passed $1bn for the first time. Debt fell by about $320m in the quarter, and there were no cash buybacks at all: the $3,046m spent in the year had already gone by June. After the borrowing of the first nine months, that is the first sign of sobriety.

Then comes the sentence. Under "Outlook", FICO writes that it is "transitioning to bespoke mortgage originations pricing, tailored to the individual needs of our customers", that it is "in the middle of this pricing transition", and that "we are not providing fiscal year 2027 guidance at this time." A company that gave a guide for 2026 and raised it in July now declines to say what next year looks like. There are honest reasons for that. Deals are unfinished and the mortgage market is weak. But think about what the words mean. For eight years FICO told the market what a score would cost, and the market wrote it down. The word "bespoke" means that there is no longer one price. The toll has become a negotiation, conducted lender by lender, and the gatekeeper does not yet know what the gate will collect. In thin trading in the first fifteen minutes after the release, the stock went from about $740 to about $630, some 10% below the close, and after the call it recovered to about $658, some 6% below. Treat those as first reactions only. At $658 the price would still be about 16% above our central value, and well above the level at which we would become interested.

The settlement is the night's good news. The release discloses a $65m accrual for "a proposed settlement of the antitrust class action lawsuits related to our Scores business". This is the case filed in 2020, consolidated before Judge Chang in Chicago, in which the claim under section 2 of the Sherman Act survived dismissal, and in which damages can be trebled. Nobody outside could put a number on that risk. If the court approves this, a suit that hung over the stock for six years will have cost about $3 a share, about three weeks of free cash flow. We would like to see the terms in the 10-K, especially any change to the contract clauses the plaintiffs attacked. It does not touch the Florida Attorney General's demand or the Senate inquiry, and it says nothing about what the Preferred Program may invite in future. Still, it removes a large unknown at a low price.

Three smaller things deserve a harder look.

First, volume. The release says B2B growth of 39% came from price, "partially offset by a decline in mortgage originations volume". In the June quarter volume was up. How much of the fall was the market, and how much was lenders dropping FICO, is the most important question in this report, and the CFO answered it on the call: volume fell by a high single digit on a year earlier, which he put down to high interest rates, and no meaningful volume went to competitors. With mortgage revenue up 72%, that means the price per score rose by about 85%, on our arithmetic. We accept this for the quarter, while noting that it is the seller's account. Scores revenue still fell about 10% from the June quarter, against about 4% a year earlier. One grid only began on 1 October, so these numbers do not yet show its effect. The first quarter that can is the one now under way.

Second, the cost of the debt. Net other expense of $29m is flattered by a $48m gain on an equity stake. Strip that out and it ran at about $77m a quarter, or about $310m a year, against $122m in all of fiscal 2025. Interest is taking about a fifth of operating profit before the one-offs.

Third, the one-offs. Non-GAAP net income of $239m excludes the settlement, $27m of restructuring and $44m of stock pay, and removes the $48m gain. Taking out the gain is honest. Taking out stock pay, as ever, is not something an owner should do. Selling, general and administrative costs rose from $126m to $225m; even if the whole settlement sits in that line, as we assume, they rose 28% before a 15% cut in positions takes effect. The CFO said that much of that saving will be reinvested, and gave no figure.

What the call added. Analysts pressed on everything the release left out, and they got a few facts and several refusals. Asked whether the average price of a FICO score will go up, down or sideways, Lansing said: "We're not going to answer that." He would not give the uptake of the Preferred Program, the other programmes on offer or the share of volume under each. The CFO gave no range for EPS. A guide will come once more of the pricing is settled, with no date. Rocket, UWM and Mr Pulte were not named at all. Lansing repeated that the gaming between the two scores is real, argued against a single grid, and said he has seen no share lost to Vantage in other lending. We would not read too much into one refusal, because these are live negotiations. But a company that had lost 62% of its value, and expected a higher average price, would have good reason to say so. That is why our central case still has mortgage revenue falling about 3% a year.

◆
Part
VI

The moat, and Buffett's prayer session

The most important decision in evaluating a business, according to the man who bought Moody's

In May 2010 Warren Buffett told the Financial Crisis Inquiry Commission that the single most important decision in evaluating a business is pricing power. Then he gave the test, talking about Moody's, another franchise wired into financial regulation. If you can raise prices without losing business to a competitor, you have a very good business. And "if you have to have a prayer session before raising the price" by a fraction of a cent, you have a terrible one.

For eight years FICO was the finest illustration of that sentence in American business. Ask what happened in October. The price decision for 2027 needed a named programme, a bundle with a second product, a commitment asked of the customer and a statement from the CEO about homeownership. That is a prayer session. It is also, at a segment margin of 91%, a very long way from a terrible business. The moat must be taken apart, because its pieces are moving in different directions.

Source of the moatBefore 2025TodayTrend
Regulatory mandateDecisive. The GSEs required Classic FICO.Gone as a mandate. Lender choice, one grid since 1 October; FHA follows on 1 January 2027.Sharply down
Common languageOne number across lenders, insurers, investors and consumers.Still real: about 94% of Fannie's Q3 loans were delivered on Classic. Weakening at the edge.Down, slowly
Switching costsHigh for a mandated input.Lower than FICO implied. Vantage comes free with FICO; about 2,000 lenders use it.Down
Low cost, high stakesThe classic defence: too small to fight over.Sound economically, lost politically. A 10:1 gap makes the fee visible.Down
Proprietary dataNever existed.The structural weakness, now binding: the data owners, distributors and rival are the same three firms.Unchanged
Non-mortgage scoresStrong.No regulator in the chain. Revenue rising. Not yet tested on price; we have no reliable data on Vantage's share here.Flat
SoftwareModerate.ARR +14%, net retention 112%, well placed with analysts' rankings; a mid-20s margin.Flat to up

What does each party really depend on? Lenders depend on whichever score the GSE grid prices, and with one grid the better number wins. Vantage scores tend to run higher: about nine points on average on Fannie loans in one study, with many buckets at 15 to 20. So a lender who pulls both can offer some borrowers a cheaper loan. Rocket says it tested 1.4m reports and that those who benefited saved $1,600 on average. Investors in agency mortgage bonds hold a government-backed guarantee, and they care about prepayments far more than default. A Santander note in September expected little effect on valuations, which undercuts FICO's claim that Vantage loans will trade worse. The dependence is real among those who hold credit risk: mortgage insurers, who must hold more capital on Vantage-only loans, and credit-risk investors. And there is a warning from Fannie Mae itself, whose latest 10-Q says the move could change the credit quality of what it buys and lower its guaranty fees.

Our verdict is that a government-conferred toll has become a commercial standard that must defend itself. That is still a business, and possibly a very good one. But it is no longer the business that traded at 40 times forward earnings, and a moat that a regulator can drain by post should be valued differently from one that he cannot reach. We score it 6 out of 10, down from what would have been 9 two years ago.

◆
Part
VII

Broken or paused? The question that sets the value

Four falls, one idea, and what lenders are actually doing

Four days that took more than half the priceClose-to-close fall, %, and what the market had just learned.30 Jul−17.0%Guide below hopes; "we're seeing gaming"4 Sep−16.7%Pulte: all lenders may use Vantage. "No more"29 Sep−26.5%One pricing grid, and Rocket's default26 Oct−13.2%$10 held flat: no rise for 2027★ All four were about one thing: who sets the price of a mortgage score.Behaviour has moved further than revenueVantageScore 4.0 in mortgages, latest reading, %.In Fannie DU applications37%In mortgage credit pulls35%Lenders on Vantage alone10%Fannie Q3 loans delivered on it6%FICO is paid on the pull, so most of this is still extra business for it. The amber bar is the one to watch:200+ of about 2,000 lenders have stopped buying FICO at all. Bureau and Fannie data, so read with care.Sources: Yahoo closes; Fannie Mae Q3 10-Q; Equifax and TransUnion calls via trade press.

The fall on 26 October is the one to think about. FICO announced that it would hold the price flat at $10 for lenders who commit to it, in a bundle with its newer score, 10T. It reported no bad number. The stock fell 13%, because the market had capitalised a rise every year for ever. Mizuho had modelled only about 5% for 2027, after a year in which FICO's take doubled. So a modest assumption went, and with it the multiple.

The Preferred Program, as far as anyone can tell. $10 wholesale per score, flat on the year, sold through participating resellers, with Classic and 10T together. Reports from Reuters and HousingWire say lenders commit to pull FICO on 100% of files. That condition is not in the release. It is reported to be non-exclusive, so a lender may add Vantage but not substitute it. It needs no sign-off from the FHFA. HousingWire, citing unnamed sources, also reports an alternative annual subscription based on prior-year volume, and a date of 31 January for lenders to choose a path. Tonight FICO says that "several deals" have been announced and that it is working with others on programmes for calendar 2027. It does not name them, and neither did the call, so we do not know whether Rocket or UWM, which together are about 95% of Vantage volume so far, are among them. Lansing said that many lenders are in talks, and would not put a number on uptake.

The case for broken. There is no headline rise for the first time since 2018. FICO had to give something away and ask for something back, and a true monopolist does neither. The rival is at a tenth of the price, committed through 2028. Every future rise now has a political cost, and Mr Pulte's reaction to a flat price was to say that more action was coming. JPMorgan now calls it closer to a mid-single-digit revenue grower.

The case for paused. FICO did not cut the $10. It held a premium of ten to one, and early checks say most lenders will pay it. A business with no pricing power does not hold ten to one. About 94% of Fannie's third-quarter loans were still delivered on Classic. Mr Pulte holds an office, not a law. And if loans priced on Vantage turn out worse, which Milliman, AEI and Arch all warn about in different ways, the argument could swing back.

Our reading. "Paused" is too kind and "broken" is premature. The annual, unilateral price lever in conforming mortgages is broken, and a conditional toll survives. Three distinctions matter.

Holding a price and raising it are different powers. FICO has shown the first and lost the second, in the channel that produces about two-fifths of its revenue.

Today's revenue rests on a strange foundation. Lenders pay FICO partly to find out whether another number is higher. Lansing calls this gaming and calls lender choice bad policy, and he is right that it benefits from the behaviour he condemns: to game the two scores you must buy both. His estimate that Vantage would reach somewhere in the 20s as a share was tied to that gaming, and he gave it before Rocket's default and the single grid.

The test is pull share, not delivered share. FICO is paid on the pull. The 6% of Fannie deliveries is the comforting number and the 37% of DU applications is the frightening one, and neither measures the money. The figure to watch is the 200-odd lenders who, on Equifax's account, use Vantage alone. Each of them is a lender who has found that it can stop buying FICO. Bi-merge would be the other mechanical blow. If Fannie and Freddie moved from three bureau reports to two, FICO would lose a third of its scores per borrower on those loans, on our reading. The order was reported as planned in early October. We can find no order as of today, and when asked on the call, Lansing had nothing to report.

◆
Part
VIII

Competition — a fight with three sides

The rival is owned by the customers, the customers are attacked by the regulator, and the regulator controls the buyers

ThreatRatingWhy
FHFA and Mr PulteCriticalSets the rules, moves by post, is hostile and has said he is not finished. On 26 October he promised more action that week; we can find none so far.
VantageScore 4.0HighEqual on the grid, $0.99 or free, in 37% of September DU applications. Additive so far.
The bureaus' pricingHighThree distributors with every reason to move customers, and a price committed through 2028.
Bi-mergeHigh, unresolvedFewer bureau pulls, fewer FICO scores. MBA's CEO expects tri-merge to go. The bureaus oppose it too.
FHA (1 January 2027)MediumThe second federal channel opens to Vantage and 10T.
10T cannibalising ClassicMediumBundled free. It adds no revenue unless priced apart. FHFA still says Classic will be retired at a future date.
GSE scores, new entrantsLow to mediumFannie's MBS files now show proprietary GSE scores. No authorisation yet. CHLA wants up to four suppliers.
Software rivals, AIMediumNICE Actimize, SAS, Pegasystems, Experian and others. AI lowering barriers is unproven in the numbers.
Vantage outside mortgagesUnknownThe largest gap in our evidence. We found no reliable share data for auto or cards.

The rival's price. In October 2025 the bureaus priced VantageScore at $4 to $4.50 and offered it free with FICO. By 9 March 2026 they had all cut it to about a dollar. By September TransUnion had fixed $0.99 to December 2028, and Equifax $1 through 2028. A firm that cuts its price that fast does not expect to make much money on the product. Equifax says that full conversion from FICO to Vantage would add only about $35m of margin. So their motive looks less like a new profit pool and more like removing FICO's threat to go around them, and escaping the dilution of its royalties. That is why we expect them to keep at it whatever Vantage itself earns.

Who is moving. Rocket made Vantage its default on eligible direct-to-consumer GSE and VA loans from the fourth quarter, keeping FICO on FHA, jumbo and others. UWM said about a quarter of its borrowers do better on Vantage. Pennymac has rolled it out across all channels. Rocket and UWM were about 95% of Vantage volume in September, on KBW's figures, at penetration of 34% and 25%. The whole shift so far rests on two very large companies that had the systems to do it. The test is whether the next hundred lenders follow.

Both sides' evidence needs care. Fannie's 6% is the cleanest number we have, and it is from before the grid. FICO's strongest evidence for 10T comes from Milliman under a consulting engagement with FICO. Vantage's strongest adoption figures come from itself and its owners. On predictive power, AEI's researchers find the two broadly similar. We would not buy or sell this stock on a claim that one score predicts default much better than the other.

The consumer brand is still strong. People know their FICO score. But lender choice moves the decision further from borrowers, who care what rate they get and not which number produced it.

◆
Part
IX

Management, the borrowed buyback and who owns it

A brilliant fourteen years, one very expensive summer, and a CEO who runs the most contested business himself

W
William (Will) Lansing · CEO (since January 2012); director since 2006
Age 67 in the 2026 proxy, confirmed as CEO in tonight's release. Has run Scores directly since James Wehmann retired in September 2025. FY2025 pay $36.0m. A $30m retention award runs to June 2028; half is options on 52,082 shares at $791.60, under water at this price. Sold about $97m of stock in 2025, on the sampled forms under a 10b5-1 plan, at about $1,720; none reported since November 2025.
S
Steven Weber · EVP & CFO
Said in July that cash would go to paying down debt in the near term. The fourth quarter bore that out. Sold $6.3m in 2025.
B
Braden Kelly · Independent Chair (since 2016)
Age 55; re-elected in March with about 13% of votes against. Sold $9.1m at about $2,343 in November 2024; exercised options in August 2026 with no sale reported.

Credit where due. Between January 2012 and the peak Lansing turned $36 into $2,382. He found the pricing power that thirty years of management had left on the table, he retired about two-fifths of the shares, and he did it with almost no capital. In management's defence on the last two years, the threat came from a change in Washington which nobody could have forecast in detail.

But the summer of 2026 is hard to defend. FICO bought back $3.05bn of stock in fiscal 2026, about three times its free cash flow. The biggest single piece came on 5 June, when it borrowed $1.5bn on a two-year term loan and paid it all to Wells Fargo for an accelerated repurchase, at a stock price of about $1,137. FHFA had started the Vantage rollout six weeks earlier, and the bureaus had cut to $1 in March. The danger was on the table. Fifty-five days later the stock fell 17% in a day, and 117 days later it closed at $592. The morning after that, management committed to cutting 15% of positions.

The borrowed buybackAverage price paid per share in fiscal 2026, against the 4 November close.$1,716Q1$1,251Q2$1,149Q3$701Close, 4 Nov★ $3.05bn in the year, about three times free cash flow; none in the fourth quarter.The 2.28m shares delivered by June cost about $1,194 each: a paper loss of about $1.1bn at this price.Debt: what paid for itTotal debt, $ billions, at each quarter end.3.06Sep 253.23Dec 253.66Mar 265.58Jun 265.26Sep 26Allowed leverage falls to 4.0× at 31 December and 3.5× a year later; ~$1.8bn falls due in mid-2028.Sources: FICO 10-Qs, Q4 2026 release, Q1–Q3 2026 calls; our arithmetic.

To be fair, the 2.28m shares delivered by June, at about $1,194, were bought by a board acting on a view of value and not a formula, and a low price during the term of the repurchase delivers more shares at settlement. Neither the release nor the call gives the final figure, though Lansing put the year at 2.514m shares for $3.03bn. But the charge against it is not bad timing. A company borrowed two-year money, against negative equity, to buy stock, at the moment when the risk to its franchise became visible. Buffett's test for a buyback is that the shares must be bought below intrinsic value, conservatively worked out. Our central value today is less than half of what FICO paid. That paper loss of about $1.1bn is more than a full year of free cash flow.

The debt. Total debt is $5.26bn, against $3.06bn a year ago, at an average rate of 5.64%, with $269m of cash and marketable investments and $338m due within twelve months. We put net debt at about 3.7 times EBITDA after stock pay. With stock pay added back, as covenants commonly do, it is about 3.3 times, in line with the 3.29× Lansing gave on the call. The covenant limit falls from 4.5× to 4.0× on 31 December 2026 and 3.5× a year later. We cannot compute the covenant ratio because its definition is not in the 10-Q, but on these figures there is room. About $1.76bn falls due within five weeks in mid-2028: the balance of the term loan and $900m of 4% notes, which would refinance at something more like 6%. With about $1bn of free cash flow, this is manageable. It does mean that the buyback, the engine of per-share growth for fourteen years, must stay small for a while. Stress it. If mortgage revenue fell 30%, EBITDA would lose about $280m. With stock pay added back, today's net debt would then be about 4.0×, through the 2027 limit; with about $1bn paid down by that date, it would be about 3.2×. So FICO can survive that outcome, provided it stops buying stock. It has no room to do both. That is why one remark on the call matters. Lansing described the pause as lasting a quarter or two and told holders to expect FICO back in the market using its free cash flow, while the CFO would not set a timeline. The same dollar cannot both repay debt and retire shares. If mortgage revenue holds, that is a fair choice. If it does not, it is the summer's mistake on a smaller scale.

Ownership — from the proxy, 13Fs and Form 4 filings
Institutions
Capital Group ~11% · Vanguard units · BlackRock
Capital Research 5.6% and Capital International 5.4% (13G, August 2026). Directors and officers together about 3%, including options.
★ Value investors
Akre 361,826 shares
8.4% of Akre's 13F book at 30 June, built from almost nothing in a year; worth about $254m at this price. Fundsmith appeared in the June quarter with a small position. We checked about twenty other well-known value and activist names and found none.
★ Insiders
No purchases · ~$175m sold
No open-market purchase by any insider since October 2024, including after the falls, though a pre-results blackout may explain recent weeks. About $174.6m sold in that time, much of it near the highs.
★ Berkshire Hathaway
None at 30 June 2026
No position in the last 13F. The September filing is due around 16 November, and is the first that could show anything about the crash.

Succession. The CEO is 67, personally runs the segment under attack, has no named deputy for it, and has a retention arrangement that ends in June 2028, the month that $900m of notes fall due. No successor has been reported. In a calm year that would be a footnote. It is more than that when the job is a lender-by-lender negotiation with an industry that feels it has been overcharged, conducted under the eye of a hostile regulator.

Integrity. We see no sign of anything improper. FICO's statements on price have been carefully worded, and in places too clever: "no increase in per score fees for lenders" sat next to mortgage revenue up 97%. Each is accurate. Taken together they explain why the company has so few friends in Washington. We take a little off the score for that, and more for the buyback. The 5 is for capital allocation at the worst moment, not for a career.

◆
Part
X

The numbers, and what the feed gets wrong

Ten years of fiscal data, one balance sheet turned inside out, and six faults in the screens

Fiscal yearRevenueOp. incomeMarginEPSDebtEquity
2016$881m$170m19%$3.39$0.57bn$0.45bn
2021$1,317m$505m38%$13.40$1.34bn−$0.11bn
2023$1,514m$643m42%$16.93$1.90bn−$0.69bn
2024$1,718m$734m43%$20.45$2.24bn−$0.96bn
2025$1,991m$925m46%$26.54$3.06bn−$1.75bn
2026$2,535m$1,266m50%$36.32$5.26bn−$3.87bn

This is about as good as a ten-year record gets. Revenue has nearly tripled, operating margin has gone from 19% to 50%, and EPS has grown more than tenfold, about 27% a year. Notice how much of the recent acceleration is one lever. From 2023 to 2026, Scores added $878m of revenue and Software $143m. Without the mortgage price, we think this would be a pleasant 8–10% grower. The past three years of growth cannot be extrapolated, because the thing that drove them has stopped.

The balance sheet deserves a word. Negative equity of $3.87bn is not a hole in the usual sense. It is the record of $9.5bn paid out for stock in a business that needs almost no assets. Total assets are just $2.08bn, of which $792m is goodwill. It does mean that there is no cushion of any kind between the lenders and the franchise, and that the value of the shares is entirely the value of future tolls.

Dividend. FICO stopped paying in May 2017, so our six dividend tests do not apply. All capital return has gone through buybacks, and for the moment that channel is closed by the debt. A shareholder gets no cash while waiting, which matters for anyone used to being paid to be patient.

★ Six faults in the feed — read these before trusting a screen
The screen saysWhat it really means
ROE −33%, P/B −3.96Both are artefacts of negative equity. They say nothing about the business. Ignore them.
Altman Z 8.4 — "safe"The score leans on market value against liabilities. It flatters a company whose shares were high, and it knows nothing of covenants or of one regulator. Net debt is about 3.7× EBITDA. The balance sheet deserves less comfort than that.
ROIC 59%True in spirit: almost no capital is employed. The precise figure depends on an invested-capital base of about $1bn, and it says nothing about whether the return will last.
FY2025 FCF $770m; P/FCF 15.5The vendor's capex of $9m leaves out capitalised software. FICO's own measure was $739m on capex of $39m. In fiscal 2026 it was $1,034m after $38m. Use the company's figure, and take off stock pay.
Product segments summing to $2.78bn in FY2025Reported revenue was $1.99bn. The vendor's table repeats old and new segment labels and so counts the same dollars twice. Read segment numbers from the filings.
Consensus EPS to $62.78 in FY2030All of it pre-dates tonight's missing guide, and the 2030 figure rests on one analyst for EPS. The FY2029 estimate of $50.64 is flat on FY2028's $50.59. These are not forecasts worth paying for.
◆
Part
XI

Valuation — what is left of the toll?

An enterprise model by revenue line, because the three lines no longer deserve the same multiple

Non-GAAP EPS, FY26
$42.99
Company measure: adds back stock pay and restructuring. ~16×.
Owner earnings ◆
~$40
Free cash flow of $1,034m less $185m of stock pay: ~$850m, on ~21.3m shares (our estimate; the final repurchase count is in neither the release nor the call). ~17.5×.
Free cash flow, FY26
~$48.60
$1,034m, company measure. Yield about 6.9% on a market value of about $14.9bn. ~14×.

Why ~$40. We reach about the same place from two directions. From cash: free cash flow less stock pay gives about $850m. From earnings: net income of $835m, plus the settlement and restructuring, less the gain, gives about $870m after tax. A full year of the September quarter's interest takes off about $70m, and a full year at $10, against one quarter at the old price, adds about as much back. That points to $40–$42 on today's share count, and we use about $40. It is before any 2027 price concession.

The enterprise model. We start from a run-rate of about $1.05bn of mortgage revenue (not the June quarter annualised, which is the seasonal peak), $0.69bn of other Scores, and $0.94bn of Software. We take off about $0.40bn a year for corporate costs, stock pay and amortisation after the staff cut, and tax at 26%, the rate the CFO gave for fiscal 2027. We discount operating profit after tax to 2031 at 10%, add a terminal multiple, and subtract net debt of about $5.06bn including the settlement. The CFO's remark about reinvesting the savings makes our 30% Software margin a little less safe.

To 2031The toll brokenThe toll conditionalThe toll restored
What happensBi-merge, big lenders leave, discounts spreadMost lenders stay at about $10; slow erosionVantage stalls, policy turns, price rises resume
Mortgage revenue−15%, −20%, −15%, −10%, −5%: $0.52bn−3% a year: $0.90bn+4% a year: $1.28bn
Other Scores, a year+3%+6%+9%
Software, a year+6%+9%+12%
Margins: Scores / Software85% / 28%88% / 30%90% / 32%
Multiple of 2031 profit12×17×21×
Value today, 10%~$190~$565~$1,025

The central value moves to about $600 at a 9% discount rate and $535 at 11%; to about $495 at an exit multiple of 15× and $670 at 20×. If mortgage revenue merely stays flat, it is about $625; if it falls 6% a year, about $515. What is priced in? At $701, on the central assumptions for everything else, mortgage revenue must grow about 3.5% a year if the business then sells for 17 times profit, or about 7% a year at 15 times. So at this price you need the toll to rise, or the multiple to stay high, and the company has just told us that it cannot yet say which way the price will go.

Why such a wide range? Because of the debt. Net debt takes about 30% of enterprise value, and it stays fixed while the rest moves. Each 5% change in the value of the business is about 7% on the shares. The low case is $190 and not $400 for that reason. It is also why we would not use the fall from the top as a guide. A stock that has lost 62% can lose half again, and in the low case it does.

Multiples on the consensus. On estimates made before tonight, the shares trade on about 15× fiscal 2027 EPS ($45.76) and 14× fiscal 2028 ($50.59). Those will move. Analysts' mean target before the results was about $1,025, in a range of $700 to $1,675, and it has been falling fast.

A comparison. Our X-Ray of Booking Holdings, written the same day, has that stock at about 17 times owner earnings. FICO sits on nearly the same multiple. Booking has net debt of 0.4 times EBITDA, and needs 4% growth to pay 10%, with no agency able to rewrite its price. FICO has 3.7 times, and a regulator who has already done so. The same multiple does not make them the same value. Our figure for FICO is below the price, and for Booking above it.

Low, central, the price and high — interest below ~$425
$190
$565
$701
$1,025
$180$1,100
★ Wait; interest below ~$425. The price is about 24% above our central value of ~$565, inside a very wide range, on ~17.5× owner earnings. Analysts' mean before results: ~$1,025. → Interactive valuation on the company page

Why $425? It is 25% below our central value and under 11 times owner earnings. For a business we rate 2 out of 5 on what can be known, the usual rule would ask for more, and we would not argue with anyone who waited for less. But at $425 the market would be pricing something close to a steady decline in mortgage revenue, with the Software and non-mortgage lines thrown in cheaply, and the buyer would make about 2.4 times the money in the high case and lose a little over half in the low one. The closing low so far is $592.47, so the market has not offered that yet.

◆
Part
XII

Risks, lawsuits & controversies

Verified 4 November 2026 against the release, the June 10-Q and public records. The 10-K, usually filed within days, may add to this

FHFA: further action promised; bi-merge reported as plannedVantage at $0.99 through 2028, equal on the gridNo fiscal 2027 guide; "bespoke" pricingDebt $5.26bn; covenant 4.0× at 31 Dec, 3.5× a year laterFlorida AG antitrust demand (1 July)Senate inquiry; FTC asked to actWeak mortgage market; rates above 7%Three bureaus were 63% of June-quarter revenueCEO aged 67 runs Scores; no successor named15% staff cut during a Platform migrationClass action: $65m proposed settlementFCF over $1bn; buybacks paused; debt fallingSoftware ARR +14%

The lawsuits. In re FICO Antitrust Litigation (N.D. Ill., No. 1:20-cv-02114) is the class action filed in 2020. The June 10-Q had it in discovery with FICO intending to defend vigorously. Tonight's release books $65m for a proposed settlement. It will need court approval, and we have not seen the terms. An earlier ruling described allegations about contract clauses, including a penalty rate on lenders who bought FICO and Vantage together; those remain allegations. The Florida Attorney General served a civil investigative demand on 1 July, asking for pricing, licensing and exclusionary-contract records and everything produced in the federal case. It did not appear in the June 10-Q, and we can find no later status. Senator Hawley opened a subcommittee inquiry on 23 March and asked the FTC to act; we can find no public outcome. An earlier DOJ investigation closed in December 2020 without enforcement. We found no filed securities suit, only plaintiff-firm notices from April, which is worth checking again after a fall of this size. And we found no suit by FICO against the FHFA.

Our inference, not a legal opinion: the Preferred Program ties a price to pulling FICO on every file. A plaintiff or a state attorney general can be expected to compare that with the exclusionary theories already raised, and Florida's demand mentions bundling. Non-exclusivity is FICO's obvious answer. Mr Pulte's words on 26 October, about competition being real and not manipulated, suggest he has noticed. So the settlement closes the past; it does not protect the present.

Policy. FHFA says Classic is expected to be retired at a future date, though it gives none, and that lenders will eventually deliver both 10T and Vantage, with lender choice in the meantime. 10T cannot yet be delivered, and Lansing said that it is still under review at the GSEs. The direct licence is now live through resellers with about 73% of mortgage reseller volume, but their calculation of the score still awaits GSE approval.

The cycle. Thirty-year rates are above 7%, and Equifax expects 2027 mortgage transactions to fall by a high single-digit percentage. If FICO moves to funded-loan fees, which are paid only on loans that close, its revenue will become more cyclical than it has been.

An irony to end on. Fannie's share of loans to borrowers under 620 rose to 2% of acquisitions in the third quarter from under half a per cent. If credit goes wrong on loans priced by a friendlier score, FICO's argument wins and its volumes fall, at the same time.

★ How we will know — six dated tests
TestTodayWhat would change our mind
A number for 2027 (by the January quarter)None given, no dateA guide with mortgage price and volume stated. A second refusal would be worse than the first.
Preferred Program by 31 January"Several deals"; uptake undisclosedBetter: Rocket or UWM signing. Worse: large lenders refusing, or the $10 conceded in private deals.
Lenders using Vantage alone200+ of ~2,000Above 500, or any top-ten lender dropping FICO on GSE loans.
Vantage share of GSE deliveries6% at Fannie (Q3)Above 20% for two quarters would mean Lansing's ceiling was too low.
Non-mortgage pricing for 2027No plan statedA rise that sticks in auto and cards would show the power survives where no regulator stands.
Debt by September 2027$5.26bnBelow $4.5bn. Lansing expects buybacks back within a quarter or two, so this is a live test. A return to borrowed buybacks would cost the board its benefit of the doubt.
◆ PART XIII · To our shareholders
The Letter ⓘ

In 2010 I told a government commission that pricing power was the most important thing I looked for, and that if you had to hold a prayer session before raising your price, you had a terrible business. I was talking about Moody's, a company I knew well. I have been thinking about that remark this week, because I have rarely seen a better illustration of the first half of it than Fair Isaac from 2018 to 2025, or a sharper turn towards the second.

Let me be fair to this business. Two men had an idea that fifty lenders would not listen to. Thirty years later almost every mortgage in America ran on their number. A manager came along who noticed that the number was worth far more than was being charged for it, and he had the patience to rewrite the contracts. Revenue has nearly tripled in ten years, and a shareholder who held on for those ten years has made about six times the money, even after this year. I have seen few better examples of what a little-noticed toll can do.

But there was always a weak plank in the bridge. FICO never owned the data. Its three largest customers own the competing score. And the rule that made its product compulsory was written by an agency, not by the market. When you have raised a price by about sixteen times, you should expect someone to notice, and in this case the someone had a pen. I do not say he was right. FICO's score is a tiny part of what a mortgage costs. I say only that a moat which can be drained by a conservator is a different asset from one that cannot, and that should be reflected in what you pay.

Tonight's report was an interesting one. The quarter was good. Free cash flow passed a billion dollars. The great antitrust case may end for about three dollars a share, which is a good deal better than I would have guessed. And then, on a single line, the company said it was moving to "bespoke" pricing and would give no guide for next year. I do not blame them for that. It is honest. But I have spent a long life looking for businesses whose owners know what they can charge next year, and here is one telling me that it does not.

Then there is the debt. Charlie and I never much liked borrowing to buy anything, and we liked it least when the thing being bought was your own stock, at a time when your franchise was under public attack. FICO paid about $1,194 a share for over two million shares. They are $701 tonight. That money is gone, and a business with no book equity now has $5.3 billion of debt to carry through the most uncertain period in its history. It can do so, if it stops buying. Its management has paused, and that is to its credit, though it told the analysts tonight that it expects to be buying again before long. I would be slower.

What is it worth? We make it about $565, in a range from $190 to about $1,025, and that range is the most truthful number in this report. At $701 you are paying about seventeen and a half times what the owners really earn, and for that you need the mortgage toll to grow from here. That may happen. Most lenders will probably go on paying. But a fall of 62% is a statement about the past, not a margin of safety, and the two are often confused. I would wait. Below about $425 I would become interested, and I would want to have seen by then how many lenders signed, what they signed for, and whether the 200 who have stopped buying have become 500.

There is no shame in waiting. You will be told that a stock down this far must be a bargain, and it may even turn out to be one. But I have found that when a business cannot tell you what it will charge, the sensible thing is to let it find out first. The score will still be there.

— The Buffett Lens · Dividend Line Research · waiting for the price list

▲The Bull Case
★★ Most lenders are still paying — about 94% of Fannie's Q3 loans delivered on Classic; no meaningful volume lost to rivals in the quarter, the CFO says; a ten-to-one premium held; revenue +27%; a Scores margin of about 91%; a common language that insurers, investors and manual underwriting still speak.
★ A real overhang may be gone — a $65m proposed settlement of the class action, about $3 a share; free cash flow above $1bn; buybacks paused and debt down about $320m in the quarter; a 15% staff cut, though much of the saving will be reinvested.
Two lines the regulator cannot reach — non-mortgage scores growing with no one in the chain; Software revenue +19%, ARR +14%, net retention 112%. With consumer scores, these are over 60% of revenue and a growing share of the value.
▼The Bear Case
★★ The price list is gone — no fiscal 2027 guide; "bespoke" pricing; no answer on the average price; a rival at $0.99 fixed to 2028, equal on the grid; 37% of DU applications include it; 200+ lenders use it alone; bi-merge reported as planned; a regulator who has promised more.
★ Debt where the cushion should be — $5.26bn of debt, equity of −$3.87bn, interest running at about $310m a year; the covenant steps to 4.0× and 3.5×; about $1.76bn due in mid-2028; each 5% on the business is about 7% on the shares.
Capital and people — $3.05bn of buybacks in a year, about $1.1bn under water on the shares delivered by June; no insider buying after a 62% fall; a CEO aged 67 running Scores himself, with no successor named; no dividend while you wait.
Wait —
Interest Below $425
A great toll that has become a negotiation. ★ At $701.03, about 17.5× owner earnings of ~$40, the price is about 24% above our central value (~$565), inside a very wide range (~$190 to ~$1,025), and needs mortgage revenue to grow while the company declines to give a guide. Wait; interest below ~$425, and sooner if Rocket signs and the exclusive lenders stop growing. Watch the Preferred Program by 31 January, the first quarter under one grid, and the debt.
⚡This stock has moved 10% or more on six days since July. Add the $425 price trigger to your Watchlist and let it come to you.
◆ The Buffett Lens · Dividend Line Research · As of 4 Nov 2026 · Price $701.03 (4 Nov close, before the results)
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Disclaimer: This is an editorial analysis for information and education, not investment advice, and not a recommendation to buy or sell any security. ⚠️ Price and market data are from our live data pull of 4 November 2026; the price used is the 4 November close, set before FICO's fiscal Q4 results were released after the market closed, so it does not reflect them; after-hours prices mentioned are thin trades. Results, debt and buybacks are from FICO's release of 4 November 2026, its June 10-Q, its 10-K for fiscal 2025, its 2026 proxy, 8-K and Form 4 filings. Remarks from the conference call of 4 November come from a third-party transcript, not an official record. This analysis does not reflect the fiscal 2026 10-K, which had not been filed at the time of writing. Our estimates are labelled as such: the share count of about 21.3m is our estimate because the final repurchase settlement is in neither the release nor the call; the rise in price per score is our arithmetic from revenue growth and a volume fall given only as a high single digit. Terms of the Preferred Program are not public and come from trade reports, some citing unnamed sources. Adoption figures for VantageScore come in part from interested parties. The figures for Equifax and TransUnion calls come through third-party summaries. Holdings by other investors come from 13F filings at 30 June 2026 and may have changed. The Letter is written in the style of Warren Buffett for editorial purposes; Mr Buffett did not write it and has no connection with this analysis.
Dividend Line · X-Ray Analyses — written in the house methodology