These borrowers already qualified once. The refi question is about change, not re-qualification.
Every person in this 400k file closed a HECM — so HUD's age, occupancy, property, financial-assessment, counseling, and CAIVRS gates were all met at origination. The H2H refi question is narrower: (1) are they still alive, (2) has anything material changed since origination, and (3) does the new PLF math produce enough benefit to clear the 5× test? This dashboard reframes the data problem around those three questions — and shrinks the vendor stack accordingly.
FIRST_POSITION_MORTGAGE_MATURITY_DATE − 150 years gives you the exact DOB of the youngest borrower. In your sample that field is populated on 80% of records, so DOB is effectively free and in-file for four out of five borrowers; the remaining 20% can fall back to the conservative floor (62 + years since origination). What you actually need to verify in bulk collapses to three things: (1) is the borrower still alive, (2) what is the current UPB on the existing HECM, and (3) has occupancy, property-charge status, or lien position materially changed. That collapses the vendor spend from $100k+ to roughly $0.03–$0.08/record — call it $12k–$32k to sweep the whole 400k.
1. Exact DOB of youngest borrower ·
DOB_youngest = FIRST_POSITION_MORTGAGE_MATURITY_DATE − 150 years · 80% populated in your sample, median derived age 80. HECM notes mature on youngest borrower's 150th birthday, so the maturity date encodes DOB exactly. For the 20% where maturity is null, fall back to 62 + years since origination.
2. Original Maximum Claim Amount (MCA) ·
MCA_original = FIRST_POSITION_MORTGAGE_AMOUNT × 2/3 · 100% populated, median derived MCA $253k. HECM mortgages are written at 150% of MCA to absorb future negative amortization, so the recorded principal recovers the original MCA exactly. Every derived MCA in your sample sat cleanly under the FHA HECM limit for its origination year — full sanity check passes.
Combined, these two formulas give you exact DOB + original MCA + original UFMIP paid (≈2% of original MCA) on the bulk pass, which means the anti-churning MIP-credit math is fully computable from in-file data. Owner 2 DOB isn't recoverable this way — the maturity reflects only the youngest, who is already the PLF-binding borrower.
FHA HECM origination requirements — flagged by what you can assume
Borrower Already passed
- Age 62+ — exact DOB is in the file. HECM notes mature on the youngest borrower's 150th birthday, so
FIRST_POSITION_MORTGAGE_MATURITY_DATE − 150 yrsgives an exact DOB for 80% of records (median age today: 80). No vendor needed for age on the bulk pass. - Eligible non-borrowing spouse — if there was a second owner on title at origination, they were already vetted as NBS or co-borrower.
OWNER_2_FULL_NAME(40% of records) tells you whether to ask about an NBS at all. - Citizenship / lawful residency — verified at origination; doesn't need re-sourcing.
- CAIVRS / federal-debt status — was clear at origination; must be re-run at application (free, LO task).
- HUD counseling — new certificate is required for the refi, but that's an app-time workflow step, not a data-enrichment item.
Property Mostly passed · verify occupancy
- Eligible property type — already verified at origination. The property doesn't transmogrify; SFR stays SFR, FHA-approved condo stays approved (with rare de-certifications). No bulk re-check needed.
- Primary residence — this is the one property gate that can silently change. Borrower may have moved to assisted living, rented it out, or died. Check via NCOA + occupancy-refresh data source.
- FHA Minimum Property Standards — re-checked at the new appraisal; not a bulk-data problem.
- Condo de-certification — the one edge case worth checking in bulk. Free HUD Condo Approval lookup by project name for your condo subset.
Financial assessment Re-underwrite at app
- Residual income — passed once; likely still passes (Social Security and pensions are sticky). Re-documented at application. Not an enrichment target.
- Credit history — only the credit events since origination matter. Flagging material derogs (BK, judgments, tax liens) in bulk is useful for lead triage; full tri-merge is reserved for applications.
- Property-charge payment history (taxes, insurance, HOA) — this is the one FA item worth checking in bulk. A delinquency signals LESA risk and tells you if the current HECM is in payable-obligations default.
- LESA determination — calculated at underwrite; not a pre-qualification data item.
Loan math Runs on in-file data
- Principal Limit = Max Claim Amount × PLF. New MCA = lesser of current AVM or FHA HECM limit (
$1,209,750for 2025). Original MCA =FIRST_POSITION_MORTGAGE_AMOUNT × 2/3. - PLF is a function of (a) age of youngest borrower and (b) expected interest rate. Use exact age from
MATURITY_DATE − 150 yrs(80% of records) or the conservative floor (62 + years since origination) as a fallback. - Core screening calc: For every record — compute new PL → subtract current UPB + ~$15k closing-cost estimate → if positive and ≥5% of new PL, lead is workable. All inputs except UPB are derivable from the file today.
- MIP credit on refi typically zeros out the upfront MIP:
max(0, 2% × (new MCA − old MCA)). Old MCA is in-file, so this computes without servicer data.
Lien position & clean-up Check for changes
- HECM is already in first lien — but a junior lien could have been added since. Your file's
SECOND/THIRD/FOURTH_POSITION_*columns show 0% for this sample, suggesting the feed filters for HECM-only first-lien properties. Verify with your Cotality rep. - Tax / HOA / HOI delinquencies since origination can block a refi or force a LESA on the new loan. Worth a bulk sweep.
- Active foreclosure —
FORECLOSURE_STAGE_CODEis populated 10% in your sample. Upgrading Cotality to full pre-foreclosure coverage is cheaper than a third-party feed.
Counseling & disclosures Re-underwrite at app
- Fresh HUD counseling certificate required (180-day validity). Loan-officer workflow, not a bulk enrichment.
- Anti-Churning Disclosure (HUD-92901) within 3 business days of application — lender produces from the new PL math.
- TALC + amortization + loan comparison — standard lender disclosures at app.
- None of these four items is something you buy from a data vendor.
What makes a HECM eligible to be refinanced into a new HECM
1 · 18-month seasoning 95% in sample pass
HUD requires at least 18 months between the closing date of the original HECM and the application date on the new HECM.
FIRST_POSITION_MORTGAGE_DATE (100% populated). Directly computable. 38 of 40 sample records already season.2 · NRMLA 5× Benefit Test Ethics standard · not HUD
Per NRMLA Ethics Advisory Opinion 2007-1, new Principal Limit minus old Principal Limit should be ≥ 5× total closing costs of the new HECM. This is an industry self-regulatory standard enforced through NRMLA's Code of Ethics — not a HUD regulation. NRMLA members agree to honor it; non-member originators are not bound.
(New PL − Old PL) ≥ 5 × Closing Costs · ≈ $75k on a $15k-closing-cost loan
2b · 2× Benefit Test CrossCountry qualifying bar
CrossCountry's internal refi-qualification threshold: benefit diff ≥ 2× closing costs (~$30k). Any borrower who clears 2× seasoning + 2× benefit + 5% cash-available is a workable refi candidate and should be worked through to close. The 5× NRMLA standard remains the industry advisory — CrossCountry exceeds it when the math allows, but deviates down to 2× when the borrower's specific circumstances warrant it (NBS conversion, rate-driven PLF improvement, equity extraction need, etc.).
(New PL − Old PL) ≥ 2 × Closing Costs · ≈ $30k
3 · Cash-available benefit test Requires UPB
New proceeds available to the borrower (after paying off the old HECM balance + new closing costs) must be ≥ 5% of the new Principal Limit. Lender overlays often push this higher.
ESTIMATED_UNPAID_PRINCIPAL_BALANCE_UPB_ENRICHED is only populated 40% of the time. This is the #1 enrichment gap for volume.4 · MIP credit on refi Fully in-file
New UFMIP on refi = max(0, 2% × new MCA − 2% × old MCA) under current HUD rules. Often small or zero, which is what makes H2H refis economically attractive to the borrower.
FIRST_POSITION_MORTGAGE_AMOUNT × 2/3 (100% populated). Old UFMIP paid ≈ 2% × old MCA. No servicer record needed for the screen — you can run the anti-churning MIP math end-to-end on data you already own.5 · Anti-Churning Disclosure (HUD-92901) Compliance
Lender must give the borrower a side-by-side showing old vs. new PL, costs, interest rate, and estimated monthly cost-of-credit. Must be delivered within 3 business days of application. If the 5× test fails or the borrower doesn't sign, you can't close.
6 · Re-qualification items the borrower must pass again Same as origination
- Still age 62+ on title (or NBS protected).
- Still alive (biggest silent filter on a 20-year book).
- Still occupies as primary residence.
- New full financial assessment (residual income, credit, property charge history, CAIVRS).
- New HUD counseling certificate (fresh, within 180 days).
- Property still meets FHA standards (new appraisal; AVM is a screen, not a substitute).
Refi qualification on your 40-row sample (20 unique borrowers)
All qualification math runs on in-file data via three formulas: DOB = MATURITY − 150 yrs, Old MCA = AMOUNT × 2/3, and an era-aware PLF engine (4 tables covering pre-2010 Traditional, 2010–2013 Standard, 2013–2017 Unified, and 2017+ Current) that matches each origination to the HUD schedule in effect at close. New PLF uses today's 6.5% expected rate and the 2026 FHA HECM limit of $1,209,750. Closing costs modeled at $15k.
AMOUNT × 2/3) to the FHA HECM limit at origination year. If derived_MCA > 1.05 × FHA_limit, the loan is proprietary — these borrowers are ineligible for the HUD HECM-to-HECM refi program specifically (that program is FHA-insured-only), but they can still refinance into a new proprietary product from AAG HomeSafe, RMF Equity Elite, Longbridge Platinum, Finance of America HomeSafe, etc. Alternative path: pay down to under the FHA HECM limit and refi into a conventional HECM. Sample breakdown: 13 FHA HECM · 3 Proprietary · 4 Unknown (missing mortgage amount). All 3 proprietaries in this sample are 2020-originated CA properties where derived MCA runs 1.4×–4.3× the 2020 FHA limit of $765,600.5 additional records inconclusive (missing maturity or mortgage amount) — not shown in the KPI row.
Proprietary refi path · Platinum Peak Jumbo only
For the 3 jumbo-flagged borrowers (ineligible for FHA H2H), Platinum Peak is the proprietary-to-proprietary refi option. Peak PLFs range from 0.391 at age 55 to 0.611 at age 91+, applied directly to current appraised value (no MCA cap, no FHA-limit cap — though Platinum has its own max loan amount, typically $4M). Platinum Peak should not be considered for FHA HECM records — converting them out of FHA insurance defeats the whole point of an H2H refi (loss of FHA MIP structure, typically worse rate, no NRMLA 5× eligibility, higher closing costs). It's the right product only when FHA H2H is off the table.
| Borrower | Age | AVM | Peak PLF | Peak new PL | Current UPB | Gap | Verdict |
|---|
UPB < AVM × Peak_PLF − $20k is the addressable jumbo refi market. Worth running the full screen to size it.Assumptions: Peak PLF table from the Apr 2026 Platinum LTVs sheet. Assumes $4M max loan amount. Closing costs estimated at $20,000 (proprietary loans typically run higher than FHA HECM). Minimum age: 55 under Platinum (vs 62 for FHA HECM) — meaningfully widens the eligibility pool for younger borrowers. Net cash threshold: 5% of new PL, matching the standard cash-available test.
| Verdict | Borrower | Product | Loc. | Age | Orig yr | PLF era | Orig rate | Old MCA | Current AVM | Old PL | New PL | Benefit diff | NRMLA 5× | Current UPB | Cash after payoff | MIP due |
|---|
Why borrowers fail Pattern
- 2020–2022 low-rate originations dominate the fail bucket. Borrowers who locked 2.5–4% expected rates near zero-rate now face 6.5% — the PLF math runs backward, so "New PL − Old PL" is small or negative. The era-aware engine doesn't save them: the 2017+ table is already the least-generous, and today's higher rate just compresses it further.
- Proprietary/jumbo loans get filtered out before the FHA H2H benefit math. Borrower HM, Borrower RJH, and Borrower GMM all have derived MCAs above the FHA HECM limit at their origination year — they closed into private products (AAG HomeSafe, RMF Equity Elite, Longbridge Platinum, or similar). They're ineligible for HUD's HECM-to-HECM refi program specifically, but they can still refi into a new proprietary product — that's a different sales motion and a different set of underwriting rules.
- Pre-2010 Traditional-era loans with high old rates now show higher old PLs than under the flat-2017 table — Borrower SI (2006 @ 6.40%) actually flips to a negative benefit diff under the era-aware engine. Borrower DJ (2007, 82 @ close, 5.05%) drops from ~$65k to $14k diff because pre-2010 Traditional PLFs at age 82 are ~0.80 vs. 0.59 under the 2017 table.
Who to actually call Target profile
- Borrower WM (MA, 82, 2006, 6.25%) — closes all four tests including NRMLA 5×. $154k benefit diff; only "true positive" in the sample.
- Borrower HOJ (CO, 92, 2004) — pre-2010 Traditional loan, very old borrower, appreciated market. $290k benefit diff clears NRMLA 5×. Pull UPB first — if it's not pathological, this closes.
- Borrower RAA (FL, 79, 2022) — unusual: 2022 origination still clears 5×. Why? Property appreciated from $661k MCA to $1.36M (capped at $1.21M) — pure equity play. $107k diff.
- Borrower FAL (DC, 95, 2006) — clears 2× qualifying bar with $32k benefit diff. Below NRMLA 5× so the loan file needs borrower-specific rationale, but this still closes under CrossCountry's bar.
- De-prioritize 2020–2022 low-rate originations and high-value CA properties with big draws — the math nearly always fails.
Methodology. PLF engine uses four era-specific tables dispatched by origination date: pre-Oct 2010 (Traditional, HUD ML 2009-xx and earlier), Oct 2010–Sept 2013 (Standard, ML 2010-34; Saver not separately modeled — defaulted to Standard as more common), Sept 2013–Oct 2017 (Unified, ML 2013-33), Oct 2017+ (Current, ML 2017-12). Expected-rate floor: 5.0% pre-2017, 3.0% from Oct 2017. Original note rate used as proxy for origination-era expected rate (approximation; off by ~25 bps for ARMs). Today's expected rate: 6.5% (HECM ARM, April 2026). Closing costs: $15,000. 2026 FHA HECM limit: $1,209,750. For records with maturity date missing (20%), age fallback: 62 + years since origination. Accuracy ±3–5% vs. servicer computations for post-2017 loans; ±5–8% for pre-2017 due to table approximations and the Standard/Saver assumption.
Mapping each HECM-refi data point to your CoreLogic file
| Data point | Matching CoreLogic field(s) | Fill | What to do |
|---|---|---|---|
| Is the borrower still alive Top priority | Not in file | 0% | Match entire book against LADMF weekly. On a 20-year HECM book, expect 15–30% decedent rate. Every downstream dollar spent on a dead person is waste. Cheapest vendor: NTIS direct (~$995/yr) or LexisNexis Deceased (~$0.05/rec). |
| Current UPB on existing HECM Top priority | ESTIMATED_UNPAID_PRINCIPAL_BALANCE_UPB_ENRICHED | 40% | This is the only hard gap between you and the benefit test math. 40% fill is a Cotality license tier — upgrading to full servicing coverage typically pushes this to 85–95%. ICE McDash is the enterprise alternative. |
| Current home value (AVM) Already have | ESTIMATED_VALUE_MKTG | 100% | Use for the screen. Refresh with a lender-grade AVM (Clear Capital / HouseCanary) only at the LE stage on active leads. |
| Phone / email / best contact Required for outreach | Mailing address only | 0% | Append after steps 1–3 on the survivors only. Datazapp or Tracerfy at $0.02–$0.03/match is fine for a warm list; TLOxp or LexisNexis for higher confidence and TCPA defensibility. |
| Occupancy still primary residence Can silently change | OWNER_OCCUPANCY_CODE (90% show "O") | 90% | Assessor snapshot can be stale. Run NCOA + USPS CASS on the survivors; flag anyone whose mailing address drifts from situs. |
| Property-charge delinquency (tax / HOA / HOI) LESA / default risk | None direct (HOMESTEAD_EXEMPT_INDICATOR is a weak proxy) | 0% | BatchData tax-delinquency flag ($0.01/rec at Scale) is the cheap option; Cotality DataTree Tax is lender-grade; First American HOA for HOA-specific properties. |
| Foreclosure / default status Disqualifier if active | FORECLOSURE_STAGE_CODE, LAST_FORECLOSURE_TRANSACTION_DATE | 10% | Upgrade Cotality to full pre-foreclosure tier, or use Auction.com / RealtyTrac. Drops the "active foreclosure" records out of the funnel before you pay to skip-trace them. |
| New junior liens since origination Lien-position risk | SECOND/THIRD/FOURTH_POSITION_* | 0% | Your file's junior-lien columns are all 0% — verify whether your Cotality feed is filtered to first-lien-only properties. If so, request these columns unfiltered so you can see liens recorded post-HECM. |
| Exact DOB of youngest borrower Already in file — derive it | FIRST_POSITION_MORTGAGE_MATURITY_DATE − 150 yrs | 80% | HECM notes mature on the youngest borrower's 150th birthday. Subtract 150 years from FIRST_POSITION_MORTGAGE_MATURITY_DATE to get exact DOB. Validated on your 40-row sample: 80% fill, median derived age 80 (vs. 70 under the floor method). For the 20% missing maturity, fall back to 62 + years since origination. Zero vendor spend. |
Best options to fill each gap — ranked by cost
DOB / age append (the biggest blocker)
Datazapp
CheapestAffordable consumer file. Age append, phone/email, homeowner demographics. Built for real-estate marketers. Accuracy is good but not lender-grade: use as an inexpensive first pass to segment the file.
Best for: triaging 400k down to <100k "likely 62+, likely alive" leads.
TransUnion TLOxp
Lender-trustedDeep consumer identity (DOB, SSN, relatives, phones), sourced from credit header + public records. GLBA-permissible for lending. The standard in reverse-mortgage prescreening.
Best for: lender-grade DOB & identity verification pre-offer.
LexisNexis Risk — Accurint / Batch Services
Lender-trustedEquivalent alternative to TLOxp. Strong on compliance (GLBA, FCRA for prescreen-only uses) and includes Deceased Solutions as an add-on — one-stop.
Best for: bundled DOB + deceased + skip trace from one credentialed provider.
Deceased / mortality (just as critical as DOB on a 20-year book)
NTIS Limited-Access DMF
CheapestDirect access to the Social Security Death Master File. Raw file — you do your own matching. Covers 85M+ records since 1936. Requires SSA-approved NTIS certification; budget 30–60 days.
Best for: ongoing in-house match at the lowest marginal cost per 400k.
LexisNexis Deceased Solutions
TurnkeySSA DMF + state records + obituaries + funeral home + proprietary sources. Weekly updates, alerts, fuzzy matching. Saves you the matching headache.
Best for: buy once, match forever — minimal operational lift.
Experian Deceased File
TurnkeyConsumer-grade deceased file, commonly bundled with NCOA for marketing suppression. Not a substitute for LADMF where you need SSA-grade certainty.
Best for: campaign suppression before you spend on downstream enrichment.
Current HECM UPB / servicing data (your 60% UPB gap)
Cotality (CoreLogic) UPB Enriched — full coverage
Same data familyYou already have ESTIMATED_UNPAID_PRINCIPAL_BALANCE_UPB_ENRICHED. The 40% fill in your sample is a license-tier issue, not a data issue. Upgrading to Cotality's full loan-level subscription (or adding their Servicing Insights product) typically pushes this to 85–95%.
Best for: fastest path — no new vendor onboarding.
ICE Mortgage Technology (ex-Black Knight) McDash
EnterpriseThe industry reference set for loan-level servicing: UPB, current rate, delinquency, MIP paid, payoff. Covers >70% of the U.S. servicing market. Best absolute coverage and accuracy on current HECM balance data.
Best for: institutional-grade UPB, MIP history, and delinquency flags at 400k scale.
Recursion / Recontact ServiceMac / Celink direct feeds
Servicer-specificIf a subset of your 400k is serviced by a small number of HECM subservicers (Celink, PHH, Reverse Mortgage Servicing Dept., etc.), a direct data-share or CSA may be cheaper than a national feed.
Best for: if 60%+ of your book is on one or two subservicers.
Contact info (phone, email, right-party-contact)
Datazapp
CheapestPay-as-you-go, no contract, $125 minimum. Built for real-estate marketers.
Tracerfy
CheapestRock-bottom unit cost. API-first, OK for wholesale-style volume. Check TCPA-scrub yourself.
BatchData (formerly BatchSkipTracing)
PlatformFull property-data platform with contact enrichment, skip, tax delinquency, and tax-lien flags. Best if you also want property-data refresh in the same API.
AccurateAppend
EnterpriseHigher-accuracy, litigator-scrub-friendly phone/email append. Popular with call-center operations that want to avoid TCPA exposure.
TransUnion TLOxp / LexisNexis Accurint
Lender-gradeIf you're already buying DOB from one of these, adding phone/email to the same query is typically cheaper than two vendors.
Whitepages Pro / Ekata
Identity graphBest for real-time identity verification during origination (phone confidence, IP insight). Not the cheapest for 400k batch.
Tax delinquency, HOA, and property-charge risk
BatchData
CheapestTax delinquency flag, tax lien flag, and tax amount across 155M U.S. properties. Cheapest bulk source, good data for campaign filtering.
Cotality DataTree / Tax Status
Lender-gradeDirect tax-assessor data with current-year status. Used by tax-service subservicers for origination due diligence. Most accurate commercial source.
First American Data & Analytics — HOA Database
Best for HOAAll 50 states, 2,300+ counties. Tells you if a property is in an HOA, dues amount, existence of a delinquency lien, and the HOA contact. Nothing else comes close for HOA at scale.
AVM refresh / lender-grade valuation
Cotality MKTG AVM (in file)
Free to you100% fill on your sample. Use as your campaign screen value.
Clear Capital ClearAVM
Lender-gradeOne of the top-3 lender-grade AVMs. Cheaper than a BPO when you need a second opinion at LE time.
HouseCanary · Veros · Quantarium
Lender-gradeAll three are used by reverse-mortgage lenders for AVM cascades. Pick whichever integrates cleanest with your LOS.
Bankruptcy & derogatory history
LexisNexis Risk Bankruptcy / PACER
ComprehensiveFull federal court bankruptcy records via PACER, with dismissals/discharges. GLBA-permissible.
TransUnion / Experian credit prescreen
Credit-gatedTri-merge or single-bureau prescreen — gives you BK, foreclosure, tax lien, delinquency, and soft scores in one call. Requires FCRA firm-offer-of-credit at the campaign tail.
Cotality foreclosure data (in file, limited)
Low fillFORECLOSURE_STAGE_CODE and LAST_FORECLOSURE_TRANSACTION_DATE are only 10% populated. Upgrade with Cotality foreclosure/pre-foreclosure data at the same license tier.
Cheapest viable H2H-refi qualification pipeline at 400k scale
Because every borrower in the 400k already passed full HECM underwriting, the bulk-enrichment job collapses to three narrow questions: still alive?, current UPB?, and anything silently changed?. That lets the funnel below strip the book down to workable prospects at roughly $0.03–$0.08/record — an order of magnitude less than a "re-qualify from scratch" stack. Run it as a weekly batch across all 400k plus an API lane that re-scores a lead the instant a loan officer opens it.
Deceased suppression
LADMF match weekly. On a 20-year HECM book, expect 15–30% decedent rate — every downstream dollar spent on a dead person is pure waste. Cost: ~$0.003/record amortized if in-house DMF ($995/yr ÷ 400k × 52 weeks); ~$0.05 via LexisNexis Deceased if you want turnkey.
Run the full refi math in-file
DOB from MATURITY − 150y (80% exact). Original MCA from AMOUNT × 2/3 (100%). Derived UFMIP ≈ 2% × old MCA. New PL from exact age + today's rate + AVM. All of the 5%/5×/MIP tests compute without a vendor call. Cost: $0.
UPB + change-since-origination sweep
Upgrade Cotality to full UPB coverage (lift fill from 40% → 85–95%). Add NCOA + pre-foreclosure + tax-delinquency flags from the same Cotality tier or BatchData. This is the one real data spend. Cost: Cotality license delta + ~$0.01/record tax-delq.
Contact append on survivors only
After steps 1–3 the list is maybe 80k–120k workable prospects (alive, seasoned, positive benefit test, no red flags). Only now spend on phone/email. Datazapp or Tracerfy at ~$0.02–$0.03/match. Cost: ~$2k–$4k for the whole survivor set.
Recommended stack Reframed
The full bulk pass — everything you need to go from 400k raw records to a scored, ranked, contactable call list.
At pre-qual (per-lead, not per-400k) Lender-grade
Only on the ~10% of survivors a loan officer actually works. Premium data is cheap when you're only buying it for leads with a live appointment.
What you are not buying Skip these
- Bulk DOB append for 400k. Exact DOB is already recoverable from
MATURITY_DATE − 150 yrson 80% of records; the 20% remainder can ride on the conservative floor. A per-lead TLOxp append at pre-qual handles any edge case. - Bulk credit / financial-assessment data. Every record already passed FA at origination; buying tri-merges on 400k people is wasted spend.
- Bulk property-type / FHA-eligibility re-checks. HUD already endorsed the property once; property type is sticky.
- Enterprise loan-level feeds (McDash, etc.) at full scale. Overkill unless your Cotality rep can't deliver UPB coverage — start with the license upgrade.