New research from Andrew Davidson & Co., Inc. reinforces what we’ve long maintained: moving away from the tri-merge credit report in mortgage underwriting would introduce risk and raise costs across the system.

Using data from Equifax, Experian, and TransUnion, the study found:

• 35% of consumers had at least one score 10+ points from the tri-merge median; 18% differed by 20+ points.
• A 20-point swing can move borrowers into different GSE pricing buckets.
• Minority and lower-scoring borrowers face greater variance.
• A non–tri-merge system could enable score shopping and increase market uncertainty.

The takeaway: incomplete data increases uncertainty — and in mortgage finance, uncertainty increases costs.

The tri-merge standard exists for a reason. It’s a balanced system that protects consumers, lenders, investors, and taxpayers. If we’re serious about affordability, we should focus on true cost drivers and promote score competition — not sacrifice data quality and market stability for short-term convenience.

We appreciate AD&Co’s rigorous, data-driven analysis. The evidence is clear: accurate, comprehensive data is essential to responsible lending and sustainable homeownership.

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