When "" is passed to the non-W version of functions and a Unicode driver is in use, the driver manager passes NULL to the underlying driver.
One example of a place this would cause trouble is the catalog functions, where NULL is sometimes not acceptable when "" is, such as for the catalog or schema when SQL_ATTR_METADATA_ID is SQL_TRUE, and the user wants to get objects that do not belong to any schema or catalog.
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The Unicode to ANSI conversions probably have the same problem, but I've not tested that.