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FRC Research · CLTV Cliff Analysis · 2023–2025

The CLTV 85
Trap

At CLTV 84%, Rocket Mortgage denies about 30% of FHA applicants with your profile. At CLTV 86%, that number jumps to 84%. Same home. Two percent more borrowed. Completely different outcome.

Slide to your CLTV. See what happens at the wall.

82%
70%80%85%90%97%

The jump at CLTV 85 — 3-year verified

These are real numbers from CFPB HMDA loan-level data, 2023 and 2025. The cliff didn't move.

Lender80–84% denial85–89% denialJump20232025
Mr. Cooper4.8%5.8%+1.0pp+2.3pp+1.7pp
Guild10.8%28.5%+17.7pp+21.4pp+12.0pp
CrossCountry15.1%87.0%+71.9pp+71.5pp+47.5pp
Freedom23.3%67.7%+44.3pp+64.5pp+28.2pp
PennyMac20.5%54.0%+33.5pp+40.2pp+24.7pp
Rocket29.5%84.9%+55.4pp+46.0pp+54.9pp

Mr. Cooper is the exception, not the rule. Its CLTV-85 jump is +1.7pp — virtually nothing. Every other lender shows a wall of 12–72 points. The wall is not an FHA rule. It's a lender overlay — an internal policy. And it's different at every institution. This is what "decision surface geometry" means in practice.

Your CLTV is what it is. Your lender choice isn't.
Route to a lender with a flat surface above 85.
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Data: CFPB HMDA loan-level modified LAR 2023 and 2025. FHA products. CLTV bands: 80–84 vs 85–89. Jump = denial rate difference between bands. 2024 data also verified (CrossCountry +71.9pp, Rocket +55.4pp). Note: part of the CLTV-85 jump reflects FHA product eligibility mechanics (cash-out LTV cap 80% since 2019) — but inter-lender differences within the same band are behavioral. Not financial advice.

Related: Full decision surfaces →  |  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.