The smaller the loan, the more likely the denial — in a perfectly monotonic gradient. In 2025, FHA applications under $100K were denied 46.9% of the time; at $400K+ the rate was 18.5%. A 2.5× penalty on the smallest loans — inside the federal program built for affordable homeownership. Source: the complete 2025 CFPB HMDA FHA dataset, 1,217,297 decisioned applications.
| Loan amount | Decisioned apps (2025) | Denial rate |
|---|---|---|
| <$100K | 51,493 | 46.9% |
| $100-150K | 99,218 | 30.2% |
| $150-200K | 151,778 | 23.9% |
| $200-250K | 180,775 | 21.2% |
| $250-300K | 187,154 | 19.2% |
| $300-400K | 286,054 | 18.5% |
| $400K+ | 260,825 | 18.5% |
The denial reasons tell the real story. Above $150K, the #1 killer is math — debt-to-income ratio, rising to 38.3% of denials at $400K+. Below $150K, DTI fades (it doesn't even make the top three under $100K) and three other forces take over:
| Loan amount | Credit history | Collateral | DTI | App incomplete |
|---|---|---|---|---|
| <$100K | 29.4% | 25.9% | — | 21.4% |
| $100-150K | 26.8% | 25.2% | 22.3% | — |
| $150-200K | 26.8% | 22.1% | 27.5% | — |
| $200-250K | 25.8% | 18.2% | 31.8% | — |
| $250-300K | 24.7% | 15.6% | 35.3% | — |
| $300-400K | 23.4% | 14.1% | 37.6% | — |
| $400K+ | 19.8% | — | 38.3% | 14.9% |
① Thin files (credit history, 29.4% under $100K): small-balance borrowers are disproportionately credit-invisible — short histories, few tradelines.
② The house itself (collateral, 25.9% under $100K, melting to 14.1% at $300-400K): cheap housing stock is old housing stock — and FHA property standards fail it at appraisal. The starter home doesn't just cost less; it qualifies less.
③ Neglect (application incomplete, 21.4% under $100K): a $90K loan pays a fraction of a $400K loan's fees for the same fixed work. Files that earn less attention die of paperwork — the small-balance economics of mortgage lending, visible in the federal denial codes.
America's affordability debate focuses on finding cheap homes. This data shows a second wall behind the first: even when the cheap home exists, the small loan that buys it is the hardest loan to get. The dead zone under $150K is where the starter-home market goes to be declined.
Not a finding of impropriety: the gradient reflects applicant mix (thinner credit files at small balances), property condition, and lawful small-balance economics — not necessarily stricter judgment of identical files. And it is a national FHA pattern, not a verdict on any lender. Lender-level behavior: the top-100 table · the 11-lender deep files.