…no? Or what are the other two records? If I can control example.com, I can use an http-01 challenge to obtain a cert for example.com.
I can't do a dns-01 challenge (that would require _acme-challenge records, although even then, I'm still up to 2, not 3, records), but I don't have to do a necessarily have to do a dns-01 just to get a cert…
To be fair these days you need to spoof it in at least two locations around the world - they will query you from at least two locations. But yeah, it is bootstrapping security out of seemingly nowhere.
Even in the dns-01 case you only need the one _acme-challenge record to *get* the cert. You only need more records to be able to do something meaningful with your cert, eg A/AAAA records that point to your malicious server and serve that cert.
It’s a terrible practice designed to build a moat for billion-dollar corporations feeling scared of free Let’s Encrypt certificates turning off the money printer.