Seven years of CFPB HMDA data. Five lenders. Five states. Three loan types. The data confirms what borrowers experience: the comparable applicant profiles, radically different outcomes depending on which lender receives it.
In 2024, the FHA denial rate ranged from 19.9% (UWM) to 58.5% (Wells Fargo) — a 38.6 percentage point spread. The FHA guidelines did not change. The borrower profile did not change. Only the lender changed.
| Lender | FHA Denial Rate | vs National Avg | FHA Volume | Type |
|---|---|---|---|---|
| UWM | 19.9% | −2.5pp ← best | 74,402 | Wholesale |
| National Average | 22.5% | — | 826,925 | — |
| PennyMac | 26.6% | +4.2pp | 15,078 | Nonbank |
| Rocket Mortgage | 28.4% | +6.0pp | 66,721 | Nonbank |
| loanDepot | 37.0% | +14.6pp | 20,996 | Nonbank |
| Wells Fargo | 58.5% | +36.1pp ← worst | 848 | Large Bank |
Wells Fargo originated 2,300 FHA loans in 2018. By 2024 that fell to 848 — a 63% decline. Meanwhile, the denial rate rose from 46.7% to 58.5%. In 2020, denials exceeded originations for the first time. This is not overlay. This is strategic market exit.
CFPB data reveals that lenders apply overlay pressure in both directions simultaneously. FHA borrowers must beat agency minimums on FICO and DTI to get approved. Neither squeeze appears in any published guideline.
Source: CFPB HMDA Quarterly Graphs — Median Credit Scores and DTI by Loan Type, Home Purchase, 2018–2025.
Wells Fargo's FHA denial rate never dropped below 34% in any state with meaningful loan volume. The overlay is not regional policy adapting to local markets — it is a national institutional decision, applied uniformly.
Florida's 2022 peak: 71.0% — the highest FHA denial rate recorded in our dataset. Seven in ten FHA applicants denied at a single lender, in a single state, in a single year.
FHA home purchase applications have remained stable at 80,000–100,000 per quarter since 2018 — regardless of interest rates. Conventional applications collapsed when rates rose. FHA applications held steady because FHA borrowers have no alternative: they cannot move up to conventional. At the national denial rate of 22.5%, approximately 18,000–22,000 FHA home purchase applicants are denied every quarter.
The Overlay Friction Index (OFI) translates these five data patterns into a single quarterly signal. OFI = 47 in Q2 2026 means the market is in MODERATE re-tightening — historically consistent with the conditions shown in this dataset when lender denial rates rise above 2019 baselines.
OFI is not a prediction. It is an observation — the same kind of observation this data supports, expressed as a single calibrated number updated each quarter.