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FRC Research · Black Hole Analysis · 2025 HMDA

Every lender has a
black hole.

Data: CFPB HMDA loan-level 2025 · 882,631 FHA applications · major deep-mapped lenders
Black hole = DTI × CLTV profile where denial reaches 97–99% · min 50 applications per cell

In physics, a black hole is a region where nothing — not even light — can escape. In FHA lending, every major lender has a profile zone where applications essentially disappear. The denial rate approaches 100%. The zone is different for each lender. And most borrowers walk in without knowing it exists.

The black holes — 2025

PennyMac
99%
DTI 36–38%, CLTV 100–105% · n=249
Even at low DTI, CLTV above 100% is a near-absolute wall. 248 out of 249 similar applications were denied. The profile doesn't need high income risk — just maximum LTV.
249 applications in this cell · 2025 HMDA loan-level
Rocket Mortgage
98%
DTI 48–50%, CLTV 90–95% · n=84
When DTI crosses 48 and CLTV sits above 90, Rocket's decision surface collapses. Two risk factors compound — DTI cliff meets CLTV wall. 82 of 84 applications denied.
84 applications in this cell · 2025 HMDA loan-level
Freedom Mortgage
97%
DTI 46–48%, CLTV 100–105% · n=63
Same CLTV ceiling as PennyMac, but Freedom's black hole starts at DTI 46 rather than 36. Still near-total at 97%.
63 applications in this cell · 2025 HMDA loan-level
Guild Mortgage
82%
DTI 38–40%, CLTV 100–105% · n=258
Guild's worst zone: CLTV above 100 at moderate DTI. 82% — severe but not absolute. Guild's flat surface elsewhere makes this zone stand out sharply.
258 applications in this cell · 2025 HMDA loan-level
Mr. Cooper
65%
DTI 46–48%, CLTV 100–105% · n=66
Mr. Cooper's worst zone is 65% — high, but the weakest black hole of the group. Even at maximum stress, Mr. Cooper still approves 35% of similar profiles. No other lender comes close at this boundary.
66 applications in this cell · 2025 HMDA loan-level
CrossCountry
21%
DTI 48–50%, CLTV 80–85% · n=71
CrossCountry's worst observed zone denies only 21% — at a DTI range where Rocket denies 98%. This is the flattest decision surface in the dataset. No black hole detected.
71 applications in this cell · 2025 HMDA loan-level

The same profile. The same federal guidelines. PennyMac: 99%. CrossCountry: 21%. At CLTV 100+ and DTI 36–38%, these two lenders face the same borrower — and deliver opposite outcomes. The black hole is not the borrower. It's the door.

The escape routes — same high-DTI zone, different lender

DTI 46–48%, high CLTV — who still approves?

Mr. Cooper
65% denial — 35% approval rate
CrossCountry
21% denial — 79% approval rate
Freedom Mortgage
97% denial — 3% approval rate
Rocket Mortgage
98% denial — 2% approval rate

Why black holes form

FHA guidelines set maximum DTI at 57% with compensating factors. No federal rule creates a 99% denial zone at DTI 36%. These are lender overlays — internal policies layered on top of federal rules. Each lender builds its own geometry. Some geometries have black holes. Some don't.

The critical insight: black holes are lender-specific, not borrower-specific. A profile that disappears at PennyMac may find 79% approval at CrossCountry. The loan doesn't change. The door does.

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Data: CFPB HMDA loan-level 2025. FHA products (derived_loan_product 2 or 32). Actions originated (1) or denied (3). DTI: exact integers. CLTV: numeric. Black hole = highest denial rate cell with ≥50 applications per lender. 6 lenders: CrossCountry (LEI 549300VZVN841I2ILS84), Freedom (549300LYRWPSYPK6S325), Guild (549300AQ3T62GXDU7D76), Mr. Cooper (549300LBCBNR1OT00651, filed as Nationstar Mortgage LLC), PennyMac (RVDPPPGHCGZ40J4VQ731), Rocket (549300FGXN1K3HLB1R50, filed as Quicken Loans Inc.). Full data: _data/black_hole_2025.json. Statistical research, not financial advice.

Related: CLTV-85 Trap →  |  DTI Death Zone →  |  Two Doors →
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🔍 Also explore: All FRC Tools · Lender Comparison · FHA by State · Lender Stress Index

The part almost nobody publishes free

Prices and rates are widely reported. Whether a lender says yes is not. In the complete 2025 federal record, denial rates across the 100 largest FHA lenders ran from 1.8% to 78.7% — same programme, same year.

And it is not simply who applies where: standardizing on state, loan amount, income, debt-to-income and loan-to-value, applicant mix explains only a 2.7× range in expected outcomes.

Which lenders approve most → Your metro → Denied? →

CFPB HMDA 2025, computed by FinanceRateCalc. Covers the highest-volume lenders published per market, not all lenders. Historical observations, not predictions. CC BY 4.0, not independently reproduced.

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FinanceRateCalc · Independent analysis of the complete federal HMDA record · Measured, not assumed. · No lender or AI vendor funds or previews this work.