Note: Small lenders are pulled toward the typical Black vs. White denial-rate gap of 9.8 points, which itself varies by about 5.9 points from lender to lender, so a raw four-fifths ratio computed on a handful of applications is noisy and can flag or clear a lender by chance. 97 watch-list lenders are not flagged by the four-fifths screen even with the 100-application floor applied; a flag here is a prompt for review, not a finding.

Source: public HMDA filings, 2023 to 2025. hmda-audit analysis.