Mr. Cooper denied 25.8% of its FHA applications in 2025 — rank #7 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 3.1% at DTI 41 to 12.9% at DTI 42 — a +9.8 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 49, denial moves from 6.8% in the 90-94% band to 54.3% in the 97+% band — +47.5 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: historically stable across cycles. What Shock Beta means →
Underwriting twins (similar decision patterns): NewRez (91/100), loanDepot (86/100). Behavioral opposites: PennyMac (66/100), Rocket (57/100). If Mr. Cooper declined a file, its twins are statistically likely to read it the same way — the opposites are a different conversation. Full similarity engine →
Of 23 verified coordinates for MrCooper, 2 are points where the standard guideline answer ("FHA permits up to 57% DTI") materially misleads: the observed denial rate exceeds 50%. The sharpest: DTI 49 × CLTV 97+ → 54.3% denied.
| DTI | CLTV band | Observed denial (2025) |
|---|---|---|
| 49 | 97+ | 54.3% |
| 45 | 97+ | 54.0% |
| 47 | 97+ | 49.1% |
| 45 | 90-94 | 15.7% |
| 44 | 90-94 | 14.4% |
| 43 | 90-94 | 12.2% |
| 43 | 85-89 | 10.9% |
| 43 | 80-84 | 10.5% |
| 44 | 80-84 | 9.9% |
| 47 | 90-94 | 9.2% |
| 47 | 80-84 | 9.1% |
| 45 | 85-89 | 9.0% |
| 44 | 70-79 | 7.6% |
| 49 | 80-84 | 7.3% |
| 47 | 85-89 | 7.0% |
| 45 | 80-84 | 6.8% |
| 49 | 90-94 | 6.8% |
| 47 | 70-79 | 6.4% |
| 49 | 85-89 | 6.4% |
| 45 | 70-79 | 4.8% |
| 43 | 70-79 | 4.5% |
| 44 | 85-89 | 4.5% |
| 49 | 70-79 | 3.8% |
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.