FAIR ISAAC CORP (FICO) Risk Factors

Recent key developments

Concrete developments — dated events, named agreements and instruments, legal proceedings — that FAIR ISAAC CORP surfaced in its latest filing.

• The FHFA Director announced in July 2025 a change permitting mortgage originators to choose the credit score they submit with mortgages delivered to Fannie Mae and Freddie Mac.July 2025
• The EU AI Act entered into force on August 1, 2024, establishing requirements for the provision and use of products that leverage AI systems, including in credit scoring, with most provisions effective in 2026.August 1, 2024
• 12 CFR Part 1254 (Validation and Approval of Credit Score Models) issued by the FHFA in accordance with Section 310 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (Public Law 115-174).
• The California Consumer Privacy Act of 2018 gives California residents privacy rights; the CPRA revised and expanded its scope effective January 1, 2023, and created the California Privacy Protection Agency.January 1, 2023
• Experian, TransUnion, and Equifax have developed a credit scoring product to compete directly with our products and are actively selling that product.
• The GDPR in the E.U. and the U.K. imposes strict obligations on the collection and use of personal data and on data transfers to countries not deemed adequate.
• Laws such as the Gramm Leach Bliley Act, HIPAA as amended by HITECH, the Fair Credit Reporting Act, the Equal Credit Opportunity Act and Regulation B, and the Fair Housing Act impose obligations on us or our customers.