loan_type = 2), HECM excluded. Every figure carries a machine-readable claim passport with the source hash.
Published denial rates treat a lender as one thing: softer or stricter than the rest. Inside the federal record that turns out to be wrong for some of the largest institutions. Compare a lender to its peers inside identical cells — same state, same loan amount, same income, same DTI, same leverage — and the advantage of some lenders reverses depending on the loan.
Every published cell has its own denial rate. For each lender with at least 30 decisions inside a cell, we take the difference: cell rate minus lender rate. Positive means the lender denied less than the cell it was competing in; negative means more. Then we average by leverage band. Because the cell rate includes the lender itself, the comparison understates rather than exaggerates the gap.
| Lender | <80% CLTV | 80–90% | 90–95% | 95–96.5% | >96.5% | Swing | perm p | Flip |
|---|---|---|---|---|---|---|---|---|
| United Wholesale Mortgage | +14 / +14 129c · 7,083d | -1 / -2 39c · 2,257d | -4 / -4 42c · 2,591d | +2 / +2 334c · 32,960d | -37 / -36 19c · 1,058d | 50.8 | 0.000 | u80 -> 80-90 |
| ROCKET MORTGAGE | +2 / +2 371c · 18,058d | -12 / -14 5c · 214d | -5 / -5 7c · 319d | -4 / -4 129c · 8,185d | — | 14.1 | 0.000 | u80 -> 80-90 |
| Lennar Mortgage, LLC | — | — | — | -5 / -6 110c · 15,658d | -15 / -14 9c · 405d | 10.3 | 0.003 | — |
| DHI Mortgage Company, LTD. | — | -1 / -2 7c · 299d | +3 / +3 8c · 306d | -4 / -3 182c · 23,582d | -6 / -7 9c · 445d | 8.6 | 0.030 | 80-90 -> 90-95 |
| Ruoff Mortgage Company | — | — | — | +3 / +3 5c · 182d | +7 / +7 8c · 329d | 4.1 | 0.023 | — |
| PENNYMAC LOAN SERVICES LLC | +3 / +3 15c · 596d | — | — | -1 / -0 8c · 401d | — | 4.0 | 0.083 | u80 -> 95-96.5 |
| Kind Lending, LLC | — | — | — | -10 / -11 15c · 1,027d | -7 / -7 5c · 215d | 3.3 | 0.347 | — |
| NEW AMERICAN FUNDING, LLC. | — | — | — | +4 / +4 6c · 260d | +6 / +6 12c · 543d | 1.8 | 0.685 | — |
| CROSSCOUNTRY MORTGAGE, LLC | — | — | — | +6 / +7 67c · 3,226d | +8 / +8 19c · 778d | 1.5 | 0.161 | — |
| MOVEMENT MORTGAGE, LLC | — | — | — | +6 / +6 10c · 402d | +7 / +7 10c · 434d | 1.4 | 0.335 | — |
| CMG MORTGAGE INC | — | — | — | +6 / +6 29c · 1,622d | +7 / +7 17c · 842d | 1.3 | 0.421 | — |
| loanDepot.com LLC | -8 / -8 39c · 1,478d | — | — | -9 / -10 89c · 6,562d | — | 1.3 | 0.480 | — |
| GUILD MORTGAGE COMPANY | — | — | — | +6 / +6 30c · 1,363d | +7 / +7 35c · 1,427d | 0.7 | 0.538 | — |
| FAIRWAY INDEPENDENT MORT CORP | — | — | — | +5 / +5 5c · 182d | +5 / +6 15c · 606d | 0.5 | 0.867 | — |
Each cell shows cell-equal mean / decision-weighted mean in points, then the number of cells and the lender decisions behind them. Positive = softer than the cell. perm p is a within-lender permutation test: a lender's own cell differences are reshuffled across its bands 1,000 times, and we ask how often a swing this large appears by chance. Flip marks where the sign reverses.
| Test | What it asks | Result |
|---|---|---|
| Bootstrap flip location | Is the sign change stable, or an accident of which cells we happened to have? | The flip lands between the under-80% band and the 80–90% band in 88% of 2,000 resamples for the largest case, and 99% for the second. |
| Negative control | If this were an artefact of how cells are built, the same lender should swing on other dimensions too. | Across income bands the same lender swings 4.6 points, against 50.7 across leverage — eleven times smaller. |
| Shrinkage | Do thin bands collapse when pulled toward the lender's own average? | The extreme high-leverage band moves from −36.6 to −34.0. The 129-cell low-leverage band does not move at all. |
| Leave-one-state-out | Is one state carrying the whole thing? | Across 29 states the gap ranges 48.0 to 58.9 points against a full-sample 50.8. Removing the largest state leaves 48. |
One thing we cannot do with this file: a continuous curve of the gap against leverage. The published cells band CLTV, so the transition can only be located between bands, never at a point. Anyone reporting this as “the 80% threshold” is reading more precision than exists — including us, which is why the wording on this page says between bands.
The more useful statistic is not how soft a lender is on average but where its sign changes. Two of the largest lenders in this table cross from the soft side to the strict side at the same place: between loans under 80% leverage and loans at 80–90%. One of them then goes far further at maximum leverage. A borrower at 70% leverage and a borrower at 97% are not dealing with the same institution, even when the name on the door is identical.
Most lenders are not like this. CrossCountry, Guild, CMG and Movement sit a few points softer than their cells almost everywhere, with swings of 1 to 2 points: their advantage really is a constant. The interesting cases are the ones where it is not.
The natural next question is whether a lender's conditional surface moves over time — whether the same institution, on the same kind of file, sits differently against its peers in different periods. It is a good question and we cannot test it here.
The public HMDA record carries the activity year and nothing finer. Application date and decision date are withheld from the public file for privacy reasons, so there is no month, no quarter and no decision date to interact with. Any calendar claim built on year-level data would be invented, so we record the boundary instead: temporal_boundary: not_identified.
If a dated source becomes available, the design is already written down in the data file — one lender, two bands, four pre-specified periods, with period permutation and leave-one-period-out required before anything is published. Writing the design before the data exists is the only way to keep it from being fitted to whatever the data turns out to show.
A headline denial rate is an average over whatever mix of loans a lender happened to receive. If a lender's behaviour is conditional, that average describes no actual borrower. The practical question is not “is this lender strict?” but “is this lender strict on files like this one?” — and for at least some large institutions, the answer changes sharply with leverage.
This is also a caution about our own published tables. The lender ranking we publish is a level comparison. This page is the reminder that a level can hide a reversal.
Method family: The Door Effect (SSRN 7309319) · What Denial Rates Cannot See (SSRN 7423798, doi:10.2139/ssrn.7423798), whose first boundary — that an aggregate is not a property of its members — is what this page measures directly · LEI-keyed screen · what we tested and found nothing