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Comment

The requirements that mandate the use of Experian, Tu and Equifax along with their Trended Data and FICO scores ( Current versions or future versions) have driven the cost to applicants up disproportionately over the past 10 years. Manuals RMCR reports are a thing of the past but the "automated reports" that replaced them have now exceeded the RMCR historical cost points. For this industry ONLY, the GSEs and related investors require 3 sources of data and there are only 3 available. Consequently the 3 Credit Bureaus and FICO have a monopoly and have been free to charge whatever they choose for their data, given the industry has no option but to PAY whatever they charge. It will be worse if the VAntage Score is adopted civen it is 3 bureau owned. At least now FICO is the independent contributor in the mix. I'm sure the 3 bureaus would love to cut them, and their related costs and requirements, out of the mix. They've been trying for years. In the Auto industry a single or dula buraeu fiole with a mix of scores are used. Data costs in that industry are $1.00 - 2.00 versus $6.00 - 9.00 in the Mortgage space.

As long as the GSEs and related require the use of 3 sources out of 3, there will be no competition, prices to the applicants will continue to rise. Given the National nature of all 3 bureau coverage, the relative consistency in the 3 scoring models and those being considered, it is time to allow the Underwriting process to be conducted on a 2 bureau requirement, with the 3rd bureau optional for marginal / referral applications. Only then will their be competition of rates and quality of content.