The Signal / Policy / October 31, 2026
Rural mortgage denials: what 10.7 million applications say about credit history and appraisals
FHFA says rural mortgage denials run high “largely due to credit history and appraisal challenges.” We sorted 10.7 million HMDA purchase applications from 2024 and 2025 by county type to see which reasons lenders actually gave.
Key points
- In its June 2026 Duty to Serve proposal, FHFA says rural denials run high “largely due to credit history and appraisal challenges.” Neither source it cites, a 2012 web page and a 2024 CFPB report, discusses appraisals causing denials.
- In 2025 HMDA data, conventional purchase denials rise from 6.3% in small metro counties to 11.3% in the most remote rural counties. Per 1,000 applications, credit history denials rose from 9 in metro counties to 22 in remote rural ones.
- Collateral, the HMDA reason closest to appraisal, appears in about one in five denials in every county type. It rises most for remote rural homes valued at $600K and up, and it is the top reason on FHA, VA and USDA manufactured home loans.
- Executive Order 14393 asks regulators to consider fewer appraisals on small-balance loans, the ROAD Act opens FHA work to licensed appraisers and Freddie Mac is updating its rural appraisal training.
One sentence, two citations
FHFA’s Duty to Serve proposal blames rural denials on credit history and appraisals, and cites two sources that do not discuss appraisals
On June 24, 2026, FHFA proposed replacing the rule that sets how Fannie Mae and Freddie Mac serve three markets: manufactured housing, affordable housing preservation and rural housing.1 Describing the rural market, footnote 31 says:
“Recent analysis of Home Mortgage Disclosure Act (HMDA) data indicates that mortgage denial rates and pricing in rural areas remain elevated compared to urban areas, largely due to credit history and appraisal challenges.”
FHFA, Enterprise Duty to Serve Underserved Markets, proposed rule, footnote 311
Citation 1 / Dec. 18, 2012
0 mentions of appraisal
A National Rural Housing Coalition web page on rural poverty, housing quality and access to bank credit.2
Citation 2 / Dec. 13, 2024
1 mention of appraisal
The CFPB’s annual HMDA report names “appraisal fees” once, as an example of a closing cost. It breaks out denial rates by race, ethnicity and loan type, with no rural breakdown.3
The rule itself
0 appraisal proposals
The rest of the rural section covers income limits, which regions count as high-needs and which activities earn credit. It asks commenters nothing about appraisals.1
The rule calls this “recent analysis” of HMDA data but does not show it. Footnote 30, just above, cites FHFA’s own analysis of 2024 HMDA data for a different figure: a 65.6% denial rate on manufactured home loans titled as personal property, against 8.8% for site-built homes.1
FHFA’s Annual Housing Report, released Oct. 30, rated Fannie Mae Low Satisfactory and Freddie Mac High Satisfactory in the rural market for 2025. Freddie Mac bought 7,327 loans in high-needs rural regions against a target of 7,400. For Fannie Mae the report gives 6,688 in its text and 6,866 in its table, against a target of 6,900.6
To test the footnote, we took FFIEC’s public HMDA records for every home purchase application filed in 2024 and 2025, 10.7 million in all, and grouped them by the USDA’s nine county types, from metro counties of a million people or more to rural counties whose largest town has fewer than 5,000 people and that do not border a metro area.45 Chapter 08 describes the method.
Denial rate by USDA county type
Purchase denials rise with each step away from a metro area, and credit history rises fastest
For conventional purchase loans on site-built, owner-occupied homes, lenders denied 7.2% of decided applications in metro counties in 2025, 8.4% in rural counties next to a metro area and 9.7% in rural counties that are not. Across the nine county types, the rate climbs from 6.3% in small metro counties to 11.3% in the most remote.4
A lender can list up to four reasons for a denial. The two lines show how often credit history and collateral were among them, per 100 decided applications. Credit history goes from 1.09 in small metro counties to 2.66 in the most remote, and collateral from 1.03 to 2.18. Collateral is HMDA’s category for problems with the property, including its appraised value. Large metro counties have more collateral denials (1.64) than small ones, which narrows the overall rural gap on collateral.
- Denied, any reason
- Credit history cited, per 100
- Collateral cited, per 100
Show the numbers
| County type (USDA code) | Decided applications | Denied | Credit history per 100 | Collateral per 100 |
|---|---|---|---|---|
| 1. Metro, 1M+ people | 1,259,410 | 7.6% | 0.82 | 1.64 |
| 2. Metro, 250K to 1M | 460,150 | 6.7% | 0.99 | 1.14 |
| 3. Metro, under 250K | 187,123 | 6.3% | 1.09 | 1.03 |
| 4. Urban pop. 20K+, next to metro | 73,305 | 7.5% | 1.51 | 1.38 |
| 5. Urban pop. 20K+, not next to metro | 18,609 | 8.0% | 1.62 | 1.56 |
| 6. Urban pop. 5K to 20K, next to metro | 54,206 | 8.9% | 2.01 | 1.54 |
| 7. Urban pop. 5K to 20K, not next to metro | 24,605 | 9.8% | 2.28 | 1.89 |
| 8. Urban pop. under 5K, next to metro | 26,899 | 10.2% | 2.36 | 1.94 |
| 9. Urban pop. under 5K, not next to metro | 16,393 | 11.3% | 2.66 | 2.18 |
FHA loans show a similar climb with higher denial rates throughout, and 2024 looks like 2025. Use the buttons above the chart to switch.
Metro counties against the most rural
Per 1,000 applications, remote rural counties had 24 more denials, and 13 more of them cited credit history
Scaled to 1,000 decided applications, metro counties had 72 denials and rural counties not next to a metro had 97. Denials citing credit history rose from 9 to 22. Denials citing collateral rose from 15 to 19, about the same increase as debt-to-income. Because one denial can list several reasons, the reason rows add up to more than the total.
- Denied, any reason+24
- Debt-to-income ratio+4
- Collateral+4
- Credit history+13
- Cash for closing+2
- Metro counties
- Rural, not next to a metro
As a share of denials, collateral holds steady across the three groups while credit history nearly doubles.
- Metro counties20%
- Rural, next to a metro18%
- Rural, not next to a metro19%
- Metro counties12%
- Rural, next to a metro22%
- Rural, not next to a metro23%
A low appraisal does not always end in a denial. A buyer can renegotiate the price, bring more cash or walk away, and a walk-away is recorded as a withdrawn application. Withdrawals were not higher in rural counties: 16.1% of metro applications were withdrawn in 2025, against 14.4% and 15.4% in the two rural groups. Withdrawals have many causes, so this is a loose check.
Two places the rural pattern changes
Collateral denials run higher in remote rural counties for homes valued at $600K and up, and lead the reasons on government-backed manufactured homes

Below $300K, remote rural counties had fewer collateral denials than metro counties at the same price: under $100K, 5.21 per 100 applications against 8.06. Above $300K the order reverses. At $600K and up, remote rural applications drew collateral denials 1.81 times as often as metro ones (1.92 against 1.06 per 100), and the 2024 data shows the same pattern.4
HMDA does not say what went wrong with the property. Freddie Mac’s rural plan names “limited comparable sales and distance between homes” as rural appraisal problems (chapter 06), and those problems would be expected to grow with the size and price of the property, but the data cannot confirm that link.
- Metro counties
- Rural, not next to a metro
- Ratio, rural to metro

Manufactured homes split by loan type. Conventional manufactured home loans, which include loans on homes titled as personal property, were denied 60.1% of the time in metro counties and 59.5% in remote rural counties in 2025. Credit history appeared in 57% to 61% of those denials and collateral in about 3%.
FHA, VA and USDA manufactured home loans were denied far less often, and collateral was the most common reason given. For FHA, collateral appeared in 32% of metro denials and 34% of remote rural ones. In the reasons lenders report on conventional manufactured home loans, the gap FHFA wants to close with chattel lending is mostly a credit gap. Our manufactured housing feature covers what Fannie Mae and Freddie Mac buy today.
- Conventional59.6% denied
- FHA14.4% denied
- VA12.8% denied
- USDA22.2% denied
Applications with no location
Counting rural applications by HMDA’s metro area field sweeps in records with no location and raises the rural denial rate
Each HMDA record carries a derived metropolitan area code. A record with no county gets 99999, the same code given to non-metro counties. In 2025, 10,096 conventional site-built purchase applications had no county, and 57.4% of them were denied, with credit history in 47% of those denials.4
Counted by that field, the non-metro denial rate for this segment is 11.0%. Counted by county, it is 8.4% next to metro areas and 9.7% elsewhere. FHFA does not say which method it used. Fannie Mae’s 2025 to 2027 plan reports 2022 denial rates of 10% nationwide and 17% in high-needs rural regions, 13% and 23% for low- and moderate-income applicants, for a broader set of loans than ours and without a method note.9
- Non-metro by HMDA’s MSA field11.0%
- Rural next to a metro, by county8.4%
- Rural not next to a metro, by county9.7%
- Metro, by county7.2%
Applications with no county: 10,096 decided, 57.4% denied. The MSA-field count includes them; the county counts leave them out.
FHFA’s own research
The rural appraisal problem FHFA’s researchers measured was values coming in above the contract price
An FHFA working paper studied appraisals on purchase loans Fannie Mae and Freddie Mac acquired from 2012 to 2016. It found that “approximately 25 percent of properties in rural areas compared to 12.7 percent in urban areas are appraised at more than five percent above contract price,” and attributed the difference to “fewer comparable sales and more heterogeneity across homes.” The authors then tested automated valuation models as a more accurate way to value rural collateral.7 An appraisal well above the price overstates the equity behind the loan, which is a risk to the lender and to whoever guarantees the loan.
Rural25%
Urban12.7%
“Rural appraisals are challenging for various reasons, including limited comparable sales and distance between homes. As a result, rural appraisals may take additional time, research, and justification to determine an acceptable value for a property.”
“They are often at the mercy of local appraisers who are willing to drive two hours or more to reach a property.”
50 miles is the median radius rural and small-town appraisers report working in, against 40 miles for urban and suburban appraisers. The rural figure was 60 miles in the prior survey.
Freddie Mac’s plan adds that rural appraisals “may also cost more,” which matters more on a low-priced home, and commits to review and update the rural appraisal training it built for lenders and the rural appraisal curriculum it developed with the Appraisal Institute.8 Fannie Mae’s plan says multifamily lenders cite “valuation challenges related to the lack of comparable properties” in high-needs rural regions.9 Rural lenders’ comments on appraisal fees and travel are collected in our review of the CFPB comment letters.
Rules, orders and plans already on the books
Seven rules, orders and plans that could change how rural homes are valued or how rural borrowers qualify
Oct. 2019 In effect
Bank appraisal threshold and rural exemptionThe OCC, Federal Reserve and FDIC raised the level below which a bank may use an evaluation instead of an appraisal to $400,000 for one- to four-family homes, and added the 2018 law’s exemption for rural transactions where no appraiser is available in a reasonable time.16 It applies to banks’ own rules, not to what Fannie Mae and Freddie Mac buy.
Early 2025 In effect
Higher appraisal waiver limitsFHFA raised the loan-to-value limit for waivers on purchase loans from 80% to 90%, and to 97% when a property data collection is done instead.15 Neither company reports how often waivers are used on rural loans.
Mar. 18, 2026 Order
Executive Order 14393, section 6Directs FHFA and the bank regulators to “consider” “reducing appraisal requirements for low-risk transactions, including low loan-to-value refinancing and small-balance loans,” more use of “alternative valuation models, desktop and hybrid appraisals, and artificial intelligence valuation tools,” and simpler appraiser qualifications. It sets no deadline.12
June 24, 2026 Proposed
Duty to Serve rewriteWould let Fannie Mae and Freddie Mac take any “eligible action” consistent with the duty instead of choosing from listed activities, starting with the 2028 to 2030 plans. Valuation work in rural areas could count under that standard; the proposal does not mention it.1
July 11, 2026 Law
ROAD to Housing Act, section 403Lets state-licensed appraisers do FHA appraisals once HUD issues guidance, due March 8, 2027, adds a trainee appraiser category to the National Registry and authorizes Appraisal Subcommittee workforce grants.14 Our ROAD Act feature covers the details.
Sept. 9, 2026 In effect
VantageScore 4.0 for all Fannie Mae lendersFannie Mae opened VantageScore 4.0 to all its lenders in Desktop Underwriter under LL-2026-06, with matching loan-level pricing from Oct. 1.13 It changes how credit is scored, the reason that drives most of the rural gap in chapter 03. We found no data yet on its effect in rural counties.
2025 to 2027 Plan
Freddie Mac rural appraisal trainingFreddie Mac is reviewing its rural appraisal training for lenders and its rural appraisal curriculum with the Appraisal Institute, and says it will update and promote them.8
Three questions for FHFA
- Which HMDA analysis supports footnote 31, and did it count applications with no county as rural?
- How often are appraisal waivers and inspection-based waivers used on rural purchase loans, and how have those loans performed?
- Would rural valuation work, such as appraiser training or alternative valuation for thin markets, count as an eligible action under the rewritten Duty to Serve rule?
AI-generated illustration.
Method and limits
- Data. Every home purchase application in FFIEC’s HMDA Data Browser for 2024 (5,316,851 records) and 2025 (5,374,348), downloaded nationwide and summarized without keeping individual records.4
- Segment. Owner-occupied, first-lien, one- to four-unit, not for a business purpose. Charts in chapters 02, 03 and 05 use conventional loans on site-built homes unless labeled.
- Rural. Each record’s county is matched to USDA’s 2023 Rural-Urban Continuum Code. Codes 1 to 3 are metro. Codes 4, 6 and 8 are rural counties next to a metro area, and 5, 7 and 9 are rural counties that are not.5 Records with no county are excluded, as chapter 05 explains.
- Rates. The denial rate is denials divided by decided applications: originated, approved but not accepted, and denied. A lender can list up to four reasons per denial. We report reasons two ways: per 100 decided applications (chapters 02 and 04 and the 1,000 applications chart) and as a share of denials (the share panels in chapter 03 and the manufactured home chart). Because reasons overlap, neither adds up to the total.
- Limits. Lenders choose the reasons. “Collateral” covers appraisal and other property problems and is not the same as a low appraisal. HMDA leaves out lenders below its volume thresholds and depository institutions with no office in a metro area, so some small rural lenders are missing. Public HMDA has no credit scores, and it does not record people who never applied. Withdrawn applications usually have no property value, so withdrawals cannot be split by value.
This article is general information, not legal advice. The HMDA tables are ValuSignal analysis; every other figure is from the cited source. For how to challenge a value on a specific loan, see our reconsideration of value guide.
Sources
- FHFA, Enterprise Duty to Serve Underserved Markets, proposed rule, 91 FR 37848 (footnote 31) (June 24, 2026)
- National Rural Housing Coalition, Barriers to Affordable Rural Housing (Dec. 18, 2012)
- CFPB, 2023 Mortgage Market Activity and Trends (Dec. 13, 2024)
- FFIEC, HMDA Data Browser, 2024 and 2025 loan application records (accessed Oct. 31, 2026)
- USDA Economic Research Service, Rural-Urban Continuum Codes 2023 (2024)
- FHFA, Annual Housing Report 2026 (covers 2025) (Oct. 30, 2026)
- Bogin and Shui, Appraisal Accuracy, Automated Valuation Models, and Credit Modeling in Rural Areas, FHFA Working Paper 18-03 (April 2018)
- Freddie Mac, Duty to Serve Underserved Markets Plan 2025 to 2027 (revised) (Dec. 11, 2025)
- Fannie Mae, Duty to Serve Underserved Markets Plan 2025 to 2027 (modified) (Sept. 30, 2025)
- National Association of Realtors, 2025 Appraisal Issues Survey (Dec. 19, 2025)
- Farm Credit Council, comment to the CFPB, docket CFPB-2026-0018 (Aug. 2026)
- Executive Order 14393, Promoting Access to Mortgage Credit, 91 FR 13203 (Mar. 18, 2026)
- Fannie Mae, Lender Letter LL-2026-06, VantageScore 4.0 broad lender availability (Sept. 9, 2026, updated Sept. 30, 2026)
- 21st Century ROAD to Housing Act, Public Law 119-101 (July 11, 2026)
- FHFA, updates to Enterprise policies on appraisals, loan repurchase alternatives and pricing notifications (Oct. 28, 2024)
- OCC, Federal Reserve and FDIC, Real Estate Appraisals, final rule, 84 FR 53579 (Oct. 8, 2019)
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