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I wouldn't say as a blanket statement that mortgage scores would always be less than 08 scores, as I'm sure there are people out there with 08 scores that are < their mortgage scores. However, certain things like number of cards/accounts with balances reported will certainly impact mortgage scores more than 08 scores.
I would say it's all profile-dependent, so there's a possibility that someone could have higher mortgage scores than FICO 08 scores I'm sure.