Withdrawn · 2026-07-31

This page is no longer published and has been removed from the index. It described a quarterly overlay signal built on HMDA data.

HMDA is annual. The public loan-level file contains no decision date, so no quarterly measure can be computed from it. A signal described as quarterly implied a granularity the source does not have, and that was the reason for withdrawal rather than any change of view about the underlying pattern.

What the record does support, on an annual basis, is published here: eight-year lender trajectories and the correction log.

FRC Research Division · HMDA + CFPB Evidence Base · 2026

The Overlay
Evidence

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.

38.6pp
FHA denial rate spread between best and highest denial rate lender (2024)
~80K
FHA home purchase applicants denied annually by overlay
+98pt
FICO overlay above FHA agency minimum (580 → 678 actual median)
7 yrs
HMDA data analyzed: 2018–2024
Finding 01 — The Lender Spread

Same Profile. Same Loan Type. 38.6 Points Apart.

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.

FHA Denial Rate by Lender — 2024 · Source: CFPB HMDA Data Browser
LenderFHA Denial Ratevs National AvgFHA VolumeType
UWM19.9%−2.5pp ← best74,402Wholesale
National Average22.5%826,925
PennyMac26.6%+4.2pp15,078Nonbank
Rocket Mortgage28.4%+6.0pp66,721Nonbank
loanDepot37.0%+14.6pp20,996Nonbank
Wells Fargo58.5%+36.1pp ← worst848Large Bank
Finding 02 — Systematic Exit

Wells Fargo FHA: Seven Years of Withdrawal

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.

Wells Fargo vs Rocket Mortgage — FHA Denial Rate 2018–2024
Finding 03 — The Borrower Squeeze

Two-Directional Overlay Pressure

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.

Credit Score (FICO)
FHA Agency Minimum580
Actual Median (2025)678
↑ +98 points
Borrowers need 98pts above the agency floor to get approved in practice
Debt-to-Income (DTI)
FHA Agency Maximum57%
Actual Median (2025)47%
↓ −10 points
Borrowers need 10pp below the agency ceiling to get approved in practice

Source: CFPB HMDA Quarterly Graphs — Median Credit Scores and DTI by Loan Type, Home Purchase, 2018–2025.

Finding 04 — Overlay Is National Policy

Five States. Same Pattern.

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.

Texas
56.7%
FHA denial 2024
California
58.5%
FHA denial 2024
Florida
65.3%
FHA denial 2024 ← worst
Ohio
56.4%
FHA denial 2024
Georgia
58.6%
FHA denial 2024

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.

Finding 05 — The Structural Denial Floor

Every Year. Every Quarter.

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.

~80,000
FHA home purchase applicants denied annually
by lender overlay — not by agency rules
Estimate: 80-100K quarterly applications × 22.5% denial rate × 4 quarters
OFI Connection

What OFI Measures

The lender denial patterns (OFI) translates these five data patterns into a single quarterly signal. 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.

OFI Methodology → Historical Dashboard → Download Data (CC BY 4.0) →
Data Sources
1. CFPB HMDA Data Browser — Denial Rates by Lender and Loan Type 2018–2024 · ffiec.cfpb.gov/data-browser
2. CFPB HMDA Quarterly Graphs — Median Credit Scores by Loan Type, Home Purchase 2018–2025 · View graph
3. CFPB HMDA Quarterly Graphs — Median DTI by Loan Type, Home Purchase 2018–2025 · View graph
4. CFPB HMDA Quarterly Graphs — Application Count by Loan Type, Home Purchase 2018–2025 · View graph
5. CFPB HMDA Quarterly Graphs — Median Total Loan Costs, Home Purchase 2018–2025 · View graph
Analysis by FRC Research Division · Ziya Y., 23 years banking · OFI Methodology · Not financial advice · © 2026 · CC BY 4.0
The part almost nobody publishes free

Prices and rates are widely reported. Whether a lender says yes is not. In the complete 2025 federal record, denial rates across the 100 largest FHA lenders ran from 1.8% to 78.7% — same programme, same year.

And it is not simply who applies where: standardizing on state, loan amount, income, debt-to-income and loan-to-value, applicant mix explains only a 2.7× range in expected outcomes.

Which lenders approve most → Your metro → Denied? →

CFPB HMDA 2025, computed by FinanceRateCalc. Covers the highest-volume lenders published per market, not all lenders. Historical observations, not predictions. CC BY 4.0, not independently reproduced.

The Denial Dispatch
One finding a week from the federal mortgage record.
One chart, three paragraphs, every Saturday. Measured, not assumed.
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FinanceRateCalc · Independent analysis of the complete federal HMDA record · Measured, not assumed. · No lender or AI vendor funds or previews this work.