For the first time in more than thirty years, mortgage lenders have been granted the right to choose which credit score they use when underwriting a conforming mortgage backed by Fannie Mae and Freddie Mac (the GSEs). The stakes are high because these mortgages represent more than 50% of the U.S. mortgage market, and FICO’s longstanding monopoly as the only credit score accepted for GSE-backed mortgages enabled it to raise mortgage credit score pricing by more than 1,000% in recent years. In fact, the stakes are so high that, in 2018, the United States Congress passed a law to end the FICO mortgage credit score monopoly and allow competition in mortgage credit scores for government-backed mortgages. Since then, FICO has engaged in a misinformation campaign designed to recast Congress’s competition reforms as “credit score gaming” in an effort to protect its longstanding monopoly and circumvent the intent of the law. That narrative will not prevail.
Since May 2026, when Congress’s credit score competition law was implemented by the Federal Housing Finance Agency (FHFA), many of the nation’s largest mortgage lenders, including Rocket Mortgage, United Wholesale Mortgage and AmeriSave, have begun shifting a significant share of their mortgage originations from FICO to the VantageScore 4.0 credit score model. In just a few months, VantageScore has captured nearly 8% of the mortgage market. Competition among risk models is good for the mortgage market and does not change the underlying risk of the mortgage borrower. Instead, mortgage credit score competition and choice reduce costs for mortgage lenders and consumers. Competition and choice increase innovation and improve the safety and soundness of the mortgage system.
Credit score models are estimates of relative credit risk based on different methodologies and data. Two independently validated credit scoring models do not need to assign the same number to the same consumer. Treating differences between credit score values as ‘gaming’ obscures the important distinction that models assess credit risk using different methodologies, and this variation is a legitimate outcome of model choice and competition.
Credit Score Choice Does Not Increase the Risk of an Individual Mortgage
The notion that credit score competition and choice make a particular mortgage riskier is false. A borrower does not become more likely to default because one validated model assigns a different score than another. The borrower’s credit profile stays unchanged. Only the model’s measurement of risk changes.
In other words, the false gaming argument uses circular logic. It assumes that if a borrower receives a different score, the mortgage must somehow be riskier. However, the borrower’s risk does not change based on the score produced by a scoring model. If actual default probability stays unchanged, then the claim that score choice increases mortgage risk collapses under its own logic.
The proper way to compare two credit scoring models is through risk-based calibration using observed mortgage default probabilities. VantageScore’s mortgage research specifically evaluates the risk equivalence mapping [VantageScore Mortgage White Paper].
Credit Score Competition is Settled Policy and Settled Law
Competition among credit score providers is the result of deliberate public policy enacted by the U.S. government. Congress directed the modernization of the mortgage credit scoring framework, and the Federal Housing Finance Agency (FHFA) subsequently approved VantageScore 4.0 for use alongside Classic FICO by Fannie Mae and Freddie Mac. The current framework explicitly permits lenders to choose between approved models on a loan-by-loan basis [FHFA Credit Score Models Fact Sheet].
The objective of credit score competition was never to ensure that every model produced identical scores. The objective was to foster competition, improve risk assessment, reduce dependence on a single provider, and responsibly expand access to mortgages. That is the key point often lost in conclusions about the false myth of “gaming.”
Conclusion
Credit score choice competition is not credit score gaming. Credit score competition is a deliberate policy choice that allows lenders to choose among more modern and thoroughly validated models while encouraging innovation, improving risk assessment, and expanding responsible access to homeownership.
Dr. Andrada Pacheco, Executive Vice President and Chief Data Scientist
