NCRA and its reseller members support score competition, especially when newer score models benefit under- and unbanked consumers. Too many consumers are not getting the credit that they deserve. While Whalen believes score competition will not help consumers, the data show otherwise, especially for consumers at the margins.

Whalen wrote that the "FHA, VA and USDA do not assess loans based on risk factors like FICO scores or LTV; borrower scores are irrelevant… FHA borrowers don't need credit scores." This statement is just not true. The FHA explicitly uses minimum decision credit scores (generally 580 for 3.5% down; 500–579 with 10% down) and evaluates LTV/DTI within HUD Handbook 4000.1. USDA guidelines also address credit scores/validation and non-traditional credit when scores are below thresholds (Rural Development). VA underwriting and pricing consider credit risk. Multiple analyses show that VA loans have distinct and often favorable rate characteristics, but they are not blind to credit risk. 

A comment in the Loan Think piece about VantageScore 4.0 is misleading. Whalen wrote that "[t]here is so little data on the newer scores and no data whatsoever through a full credit cycle" that a "lender [will] be reluctant to use Vantage 4.0 or FICO 10T to underwrite conventional loans[.]" In July 2024, FHFA released 10 years of historical VantageScore 4.0 credit data, providing market participants with substantial historical performance information. Among other things, this release enables approved lenders to review that detailed information as part of their decisioning process.

The comment "loan coupons on FHA, VA and USDA are almost always significantly lower than the monthly payment on conventional loans" is overstated. It is common for FHA/VA loan rates to be lower, especially for moderate credit scores. However, a consumer's monthly payment depends on the mortgage insurance/premium, guarantee fees, and borrower profiles. Saying that these loan rates are "almost always significantly lower" is exaggerated.

There is an unsubstantiated claim in the Loan Think piece saying, "many firms prohibit LOs from showing a conventional mortgage to low-income borrowers" to avoid GSE repurchase risk. This is a broad claim about internal lender policies lacking support. This statement may be an anecdote or an opinion, but not a fact. 

The Loan Think piece implies that using rent/utility data of VantgageScore 4.0 and FICO 10T would necessarily lower secondary-market bids as opposed to the use of Classic FICO. This is a speculative assertion. Investors price overall loan-level risk with many inputs. FHFA has not mandated investor haircuts for 4.0 or 10T, and the GSEs continue to implement details on credit score model-choice.

LOANTHINK COLUMNS ON CREDIT SCORINGVantageScore's 'future of credit' rests on shaky mathFair Isaac's white paper makes it clear it is raising pricesVantageScore 4.0's predictive power stands up to scrutinyFICO isn't the problem. A premature two-score system isCredit score competition reduces mortgage market riskPulte's tweet hands credit bureaus an unfair edgeCredit scores are not the issue

The comment that "FICO's direct program eliminates the need to rely on the bureaus" is too strong and a bit premature. The nationwide bureaus play a critical role in the home loan process. While NCRA supports competition and lower costs to consumers, the FICO announcement and the bureaus' responses still require much more detail to determine the full impact. FICO's program changes score licensing/distribution, but lenders still need tri-merge credit reports from the CRAs for GSE eligibility to enable consumers to realize the American dream of homeownership. NCRA looks forward to learning more about the FICO direct option and the programs announced by the nationwide bureaus. 

The comment that "competition in credit scores is inane," is nonsensical. Score competition, backed up by empirical data collated from VantageScore, shows advantages to consumers and the American economy. 

Sadly, Whalen's Loan Think piece calls the GSEs' mission a "political farce." We agree with Director Pulte that Fannie Mae and Freddie Mac could operate more efficiently. But the GSEs remain critical to the American economy, which relies heavily on home ownership. The GSEs exist to, among other things, improve the flow of credit in the housing market, while also reducing the cost of that credit. These Enterprises are integral to the stability of financial markets. The GSEs are also committed to creating a more financially inclusive and financially empowered home-buying market by promoting safe and sound lending to underserved consumers. NCRA supports the GSEs' mission.

Director Bill Pulte is clear in his objective to make housing more affordable, and HUD Secretary Scott Turner has a strong vision to "expand the American dream of homeownership for all Americans." NCRA is on board with those principles. There is room for disagreement about credit scores, score delivery, and credit report pricing, but the discussions should be based on facts. Christopher Whalen's Oct. 14 missed the mark. Our necessary rebuttal lands on the facts.