In the high-risk FHA profile — DTI at or above 44, CLTV at or above 90 — six major lenders face the same borrowers. The market average denial rate is 59.9%. What each lender does with that profile varies by 64 percentage points.
DTI 44+, CLTV 90+ · Market average: 59.9% · 8,795 total applications
DTI 36-43, CLTV 80-89 · Market average: 12.7% · 20,040 total applications
The gap widens as profile risk increases. In the mid-risk band, the spread between best and worst is 30 points. In the high-risk band, it expands to 64 points. Risk amplifies lender divergence — it doesn't smooth it.
Scope note: Market average here is the weighted average of these 6 lenders only — not the full FHA market. Disparity is measured against observable risk variables (DTI, CLTV) available in HMDA; credit score is masked in the public file and cannot be controlled. These awards reflect loan-level patterns within this sample, not regulatory findings.
🔍 Also explore: All FRC Tools · Lender Comparison · FHA by State · Lender Stress Index