Freedom denied 24.2% of its FHA applications in 2025 — rank #5 of the 100 largest FHA lenders (1 = lowest denial), from CFPB HMDA loan-level records (1,187,606 decisioned FHA applications in 2025).
Sharpest observed DTI step: at CLTV 80-84, denial moves from 12.8% at DTI 45 to 23.2% at DTI 46 — a +10.4 point jump across one integer of DTI. FHA program rules permit DTI well above this; the desk does not.
Sharpest observed CLTV step: at DTI 43, denial moves from 5.4% in the 80-84% band to 96.1% in the 97+% band — +90.7 points on down payment alone.
Denial rates reflect applicant mix as well as underwriting strictness; overlays are lawful business decisions. Cells with n<50 excluded. Methodology
Shock profile: high market sensitivity — this door moves when rates move. What Shock Beta means →
The single deepest denial zone in Freedom’s 2025 FHA record: DTI 46–48 × CLTV 100–105% → 96.8% denial (n=63). Files entering that coordinate historically did not come out. All lenders’ black holes, mapped →
Underwriting twins (similar decision patterns): Mr. Cooper (85/100), PennyMac (83/100). Behavioral opposites: UWM (67/100), Guild (63/100). If Freedom declined a file, its twins are statistically likely to read it the same way — the opposites are a different conversation. Full similarity engine →
Of 17 verified coordinates for Freedom, 4 are points where the standard guideline answer ("FHA permits up to 57% DTI") materially misleads: the observed denial rate exceeds 50%. The sharpest: DTI 43 × CLTV 97+ → 96.1% denied.
| DTI | CLTV band | Observed denial (2025) |
|---|---|---|
| 43 | 97+ | 96.1% |
| 47 | 97+ | 96.1% |
| 49 | 97+ | 92.6% |
| 44 | 97+ | 83.0% |
| 47 | 85-89 | 28.9% |
| 45 | 85-89 | 23.6% |
| 49 | 85-89 | 15.1% |
| 45 | 80-84 | 12.8% |
| 47 | 80-84 | 10.3% |
| 47 | 70-79 | 7.9% |
| 45 | 70-79 | 7.6% |
| 43 | 80-84 | 5.4% |
| 49 | 80-84 | 5.3% |
| 44 | 80-84 | 4.2% |
| 49 | 70-79 | 3.3% |
| 43 | 70-79 | 3.2% |
| 44 | 70-79 | 3.2% |
Cells with n<50 excluded. Part of the FRC Mortgage Decision Geometry Benchmark — a free ground-truth set for testing AI answers to mortgage questions. Machine-readable: ai-benchmark.json. Denial rates reflect applicant mix as well as underwriting; overlays are lawful.