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Figure HELOC Review 2026: 33,415 Lines, 9.1% Median Rate (HMDA)

By Jorge··24 min read

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Quick Answer

As of October 22, 2026, the newest federal loan-level record (HMDA, loans made in 2025) shows Figure Lending LLC originated 33,415 home equity lines of credit with $2.925 billion in credit limits, fourth among 1,165 lenders in the file by line count, at a median note rate of 9.10% against 7.50% for all other lenders (our arithmetic). It denied 19,989 applications, 37.43% of those decided, and 1,688 of its lines (5.05%) were on investment property, where the 90th-percentile combined loan-to-value (CLTV) was 70.0% against 76.9% for other lenders. The CFPB complaint database lists 284 complaints under the name Figure Technologies, Inc, 127 of them about HELOCs, and none under Figure Lending LLC. Figure Technology Solutions, Inc (Nasdaq: FIGR) reports a matching average rate for its own-brand lines in its 10-K: 9.1% in 2025, 10.5% in 2024.

Key Takeaways

  • Scale: 33,415 lines and $2.925 billion of credit limits in 2025 (34,103 and $2.674 billion in 2024), 2.7% of all lines and the 4th largest by count, the first lender on that list that is not a bank or credit union (our arithmetic). Figure's 10-K puts its own-brand volume at $1,975.7 million for 2025; HMDA counts credit limits of every line Figure Lending closed, so the two totals are not the same measure.
  • Rate: median 9.10% in 2025, down 1.60 points from 10.70% in 2024; other lenders' median was 7.50%, a gap of 1.60 points. Only 5 of the 41 lenders with 5,000 or more lines had a higher median. Inside Figure, price rises with CLTV from 8.25% under 50% to 10.20% at 80% to 85% (principal residences).
  • Approvals: 37.43% of decided applications were denied (banks on our list ran from 36.1% to 54.4%), and 15,291 approved applications (31.4% of approvals) were not accepted by the applicant. The first reason on 37.4% of denials was debt-to-income and on 35.9% an incomplete application.
  • Rentals: 1,688 lines on investment property, 6.2% of the national total and the most of any lender. The median rate there was 9.05%, no premium over 9.10% on principal residences (other lenders: 8.50% against 7.49%). The limit is on leverage: the highest CLTV was 70.0% in 2024 and 80.0% in 2025, when 84 rental lines went above 70%.
  • Who bought the loans: 56.3% of 2025 originations were reported sold to credit unions, mortgage companies or finance companies and 17.7% to private securitizers, against 43.1% and 50.2% in 2024. Figure Lending also reported buying 37,739 lines ($3.664 billion) that others originated.
  • Complaints: 284 under Figure Technologies, Inc since 2018, 127 about HELOCs, 54 of those received in 2026 alone; 51.2% of HELOC complaints are about the payment process. In 2025 the 34 mortgage-product complaints equal 10.2 per 10,000 lines originated, inside the 6.1 to 24.8 range of eight large peers (our arithmetic; a ratio of two different populations).

CSV · 332 rows

Figure Lending HELOCs in federal HMDA data, 2024-2025: rates, CLTV, approvals, buyers, CFPB complaints and SEC filings

Figure Lending in the 2025 and 2024 HMDA files, the national comparison for open-end lines, 13 large HELOC lenders, CFPB complaint counts, Figure Technology Solutions 10-K and 10-Q figures, Figure's own pages (dated) and the Regulation C rules cited. One source per row.

What we counted, and which Figure this is

Most people searching for “figure heloc” want figure.com, and the page below it is a long list of reviews that quote an annual percentage rate range and a credit-score minimum. What they do not have is the lender’s own record. Lenders above a size threshold must report every home equity line they originate to the federal Home Mortgage Disclosure Act (HMDA) file, and the FFIEC publishes it loan by loan. For an open-end line, Regulation C says the amount reported is “the amount of credit available to the borrower under the terms of the plan” (12 CFR 1003.4(a)(7)(ii)), and the interest rate is the one “at closing or account opening” (1003.4(a)(21)).

We downloaded the 2025 and 2024 files for the legal entity identifier of Figure Lending LLC (254900UL88QFG0E40516) on October 22, 2026, and for the other lenders we used the national 2025 file of originated open-end lines (principal residence and investment property, downloaded October 7, 2026, the same extract behind our HELOC on investment property page) plus the full 2025 files of 12 large HELOC lenders. “Denial share” is denied applications divided by originated plus denied, as on our Rocket Mortgage page; withdrawn and approved-but-not-accepted applications are outside it. HMDA carries no credit scores, fees or APR for open-end lines, so none of those appear here except where a filing or Figure’s own page gives them.

Three entities share the name. Figure Lending LLC is the HMDA filer and the lender that closes the loans. Figure Technology Solutions, Inc (Nasdaq: FIGR) is the SEC registrant that owns the platform and, since September 1, 2026, Kiavi (see Figure Technology Solutions and Kiavi: what the filings say). The CFPB complaint database files everything under a third name, Figure Technologies, Inc. A search for “Figure Lending LLC” there returns zero complaints, which is why other write-ups report none.

Figure Lending’s HELOC book in 2025 and 2024

Figure Lending LLC, originated open-end lines, against all other lenders in 2025

MeasureFigure 2025Figure 2024All other lenders 2025
Originated lines33,41534,1031,177,713 lines, 1,164 lenders (occupancy 1 and 3)
Credit limits, total$2.925 billion$2.674 billionnot compared
Median credit limit$65,000$65,000$105,000
Median note rate9.10%10.70%7.50%
10th to 90th percentile note rate7.35% to 12.00%8.65% to 13.40%not compared
Median CLTV66.0%67.3%63.0%
90th percentile CLTV83.2%84.3%82.5%
Second-lien share89.7%93.0%not compared
Reported as business purpose470 (1.4%)443 (1.3%)not compared
Investment-property lines1,688 (5.05%)1,392 (4.08%)25,542 (2.17%)

Two things stand out. The book is small-ticket: half of the lines are $65,000 or less, and the median is the same in both years while the median rate fell from 10.70% to 9.10%. And it is second-lien paper: 89.7% of the lines sit behind another mortgage, so the rate on a borrower’s existing first loan decides whether a Figure line is cheaper than refinancing the whole balance (see our cash-out refinance on investment property data for the other route). The median line was originated at 7.90% when it was a first lien and 9.32% behind another mortgage (our arithmetic).

The rate: 9.10% against 7.50%

The 2025 median note rate on Figure’s lines was 9.10%, 1.60 points above the 7.50% median of every other lender. Figure had the 6th highest median of the 41 lenders that originated 5,000 or more open-end lines. The table puts it next to the 12 other large HELOC lenders whose full files we pulled.

13 large HELOC lenders, 2025 (all occupancy types in each lender’s own file)

Lender (HMDA name)Lines originatedMedian note rate90th percentile CLTVDenial shareInvestment-property lines
CITIZENS BANK, NA57,4047.65%80.0%36.1%4
Bank of America NA56,6536.24%79.6%54.4%86
PNC BANK N.A.47,9617.74%81.5%38.3%21
FIGURE LENDING LLC33,4159.10%83.2%37.4%1,688
Huntington National Bank29,5067.93%83.4%39.9%1
Navy Federal Credit Union24,9628.75%89.2%40.4%764
Fifth Third Bank, National Association23,8868.00%84.8%38.9%246
United Wholesale Mortgage14,9118.75%84.5%24.7%1,240
TD Bank14,4997.64%80.0%39.5%800
HomeBridge Financial Services, Inc12,38710.62%80.0%9.5%1,311
SPRING EQ, LLC11,7649.97%88.6%64.3%623
Lendage LLC (Achieve Loans)10,89011.00%80.0%15.9%0
loanDepot.com LLC6,4848.88%83.7%46.2%0
Better Mortgage Corporation4,2439.12%82.6%59.6%1,185

The pattern is a split between banks and credit unions (median rates from 6.24% to 8.75% in this table) and online or non-bank lenders (Figure, SpringEQ, HomeBridge, Achieve at 9.10% to 11.00%). Median rates are not APRs, and a bank that waives fees or prices a promotional rate can look cheaper or dearer than it is; the note rate is the rate at account opening (Regulation C 1003.4(a)(21)).

Figure’s price follows the amount borrowed against the home. Among its principal-residence lines:

Figure Lending, median note rate by CLTV band, principal residences

CLTV bandLines 2025Median rate 2025Lines 2024Median rate 2024
Under 50%7,5948.25%6,36510.20%
50% to under 60%4,5318.70%5,03810.30%
60% to under 70%6,0859.05%6,60910.80%
70% to under 80%7,1689.65%7,97911.20%
80% to 85%5,78410.20%6,21610.80%

In 2025 a borrower near the top of the range paid 1.95 points more than one borrowing under half the home’s value (our arithmetic). In 2024 the ladder was flatter and went the other way at the top (the 80% to 85% band was cheaper than the 70% to 80% band), which we read as a change in pricing between the two years and not a fixed feature of the product.

What the rate costs on a fully drawn line (our arithmetic). Figure’s fixed-rate line is “100% drawn at the time of origination” (its own page, captured October 22, 2026), so interest runs on the full amount from day one. On the median $65,000 line, 1.60 points is $1,040 a year in interest; on $100,000 it is $1,600 a year, before any origination fee, which Figure’s 10-K says is “calculated as a percentage of the customer’s initial loan balance”. The page we captured shows no fee percentage, so the fee has to come from the disclosure Figure gives you.

What the SEC filings say about the same book

Figure Technology Solutions, Inc reports averages for “Figure-branded” loans, those it originates under its own name, and for “Partner-branded” loans made by its 307 active partners through its software. The Figure-branded table in the 2025 10-K gives a customer interest rate of 9.1% for 2025 and 10.5% for 2024, an average FICO score of 748 and an average balance of $91 thousand; the June 30, 2026 10-Q gives 8.6% for the first half of 2026 and 8.8% for the second quarter.

HMDA against the filings

ItemHMDA (Figure Lending LLC)SEC filing (Figure Technology Solutions)
Rate, 2025median 9.10%Figure-branded customer interest rate 9.1% (10-K)
Rate, 2024median 10.70%Figure-branded customer interest rate 10.5% (10-K)
Rate, first half of 2026not published until 2027Figure-branded 8.6%; second quarter 8.8% (10-Q)
Size of the linemean credit limit $87,544, median $65,000average Figure-branded loan balance $91 thousand (10-K)
Volume, 2025$2.925 billion of credit limitsFigure-branded volume $1,975.7 million; Partner-branded $6,401.4 million; $8.3 billion of home equity lending facilitated (10-K)
Credit scorenot in HMDA for open-end linesFigure-branded average FICO 748 (10-K)
Mixall open-end linesHELOCs “over 98%” of 2025 loan originations (10-K)

The rates line up, which is the useful result: the median in the federal file matches the average in the annual report, to one decimal. The volume does not line up and should not: HMDA reports the credit limit of each line Figure Lending closed as the lender, while the 10-K reports the value of loans originated under its own brand, and Figure Lending also closes loans introduced by brokers that the company counts in its partner volume (our reading; the filings do not give the split). Partner-branded loans made by banks and credit unions on Figure’s software appear in HMDA under the partner’s name (our reading), so they are not in the numbers above.

The 10-K calls Figure “the leading originator of HELOCs among non-depository lenders” in 2025. The HMDA count agrees on the rank by lines: the three larger lenders in our extract (Citizens, Bank of America, PNC) are all banks. The 10-Q’s legal-proceedings item says Figure is “not currently a party to or aware of any proceedings” that it believes will have a material adverse effect. For the Kiavi side of the company, see our Kiavi review.

Does Figure lend against a rental? What the file shows

Yes, and at scale. Figure Lending reported 1,688 lines on investment property in 2025 (1,392 in 2024), 6.2% of the 27,230 such lines in the national file and the most of any lender, ahead of HomeBridge (1,311), United Wholesale Mortgage (1,240) and Better Mortgage (1,185). Figure’s page says its lines are offered on “eligible properties held solely, jointly, in a revocable trust, or by an LLC” and does not mention rentals, so the record is the better evidence. Our HELOC on investment property page shows the whole market; this table shows how Figure treats the three occupancy types.

Figure Lending by occupancy type, 2025

Occupancy typeLinesMedian note rate90th percentile CLTVHighest CLTVLines above 70% CLTVDenial shareMedian limit
Principal residence31,1629.10%83.8%85.0%12,31737.0%$65,000
Second residence5658.90%70.0%80.0%3543.7%$95,000
Investment property1,6889.05%70.0%80.0%8443.1%$75,000

The same, 2024

Occupancy typeLinesMedian note rate90th percentile CLTVHighest CLTVLines above 70% CLTVDenial share
Principal residence32,20710.70%84.6%85.0%13,65537.5%
Second residence50410.40%70.0%70.0%041.2%
Investment property1,39210.45%70.0%70.0%042.4%

Three readings, all ours. First, there is no investor premium at the median: 9.05% on rentals against 9.10% on principal residences, while other lenders charged 8.50% against 7.49%. Second, the price of being an investor is leverage and odds: in 2024 no non-owner-occupied line went above 70.0% CLTV, in 2025 the highest was 80.0% with 84 rental lines above 70%, and 43.1% of decided investment-property applications were denied against 37.0% on principal residences. Third, these are mostly consumer-purpose loans on a rental: only 80 of the 1,688 rental lines were reported as business purpose, so Figure’s HELOC is not a business-credit product.

If you hold the rental in an LLC and want a rental-income loan instead, Figure now sells one. Its DSCR loan page, captured October 22, 2026, lists a minimum FICO score of 660, a debt-service coverage ratio “as low as 0.8x” and a maximum CLTV of up to 80% for rate-and-term refinances and up to 75% for cash-out refinances; it is not a HELOC. Figure completed the Kiavi acquisition on September 1, 2026 (8-K), and Kiavi’s licensing page, quoted on our Figure Technology Solutions page, says its DSCR and rental loans are funded by Figure Lending LLC from that date, so the 2025 HMDA file does not show such loans under Figure Lending. Compare it with the DSCR data on our investment property loans guide.

Who ends up with the loan

Figure sells what it originates. The 10-K says it “routinely” sells HELOCs and keeps the servicing; HMDA shows to whom, by category, for the loans sold in the same calendar year.

Purchaser type of Figure Lending’s originated lines

Purchaser type20252024
Credit union, mortgage company or finance company (code 71)56.3%43.1%
Private securitizer (code 5)17.7%50.2%
Not applicable: not reported as sold in the year (code 0)20.6%5.2%
Commercial bank, savings bank or savings association (code 6)4.5%0.0%
Affiliate institution (code 8)0.8%1.5%

The mix flipped. In 2024 half of the lines went to private securitizers; in 2025 56.3% went to credit unions, mortgage companies or finance companies, which fits the whole-loan sales and the Figure Connect marketplace the 10-K describes ($3.9 billion transacted by third parties since June 2024). For a borrower the practical point is servicing and the complaint record: the company that sends the monthly statement is not necessarily the one that closed the line.

The file also shows the other side of the business. Figure Lending reported 37,739 purchased loans in 2025 ($3.664 billion of credit limits), up from 21,556 in 2024, loans that partners originated under their own brands. They are not included in any rate or CLTV figure above. The 10-K says the company “enters into agreements with various loan origination partners to purchase and service the loans they originate.” A HELOC from a local credit union or a home-improvement brand can therefore end up on Figure’s books.

Approval odds: where the applications went

Of 72,355 applications Figure Lending recorded in 2025 (excluding the 37,739 purchases), 33,415 ended in a loan (46.2%), 19,989 were denied, 3,660 were withdrawn by the applicant and 15,291 were approved but not accepted (our arithmetic).

Figure Lending application outcomes

Outcome20252024
Originated33,41534,103
Approved but not accepted15,29114,825
Denied19,98920,737
Withdrawn by applicant3,6604,208
Denial share (denied / originated plus denied)37.43%37.81%
Share of approvals not accepted31.4%30.3%

A 37.4% denial share is not unusual for a large HELOC lender. In our 13-lender table it sits between Citizens Bank (36.1%) and Huntington (39.9%), above United Wholesale (24.7%), HomeBridge (9.5%) and Achieve (15.9%), and below Bank of America (54.4%), Better Mortgage (59.6%) and SpringEQ (64.3%). Denial shares are not comparable across lenders without knowing how each sorts failed applications into denied, withdrawn and closed-for-incompleteness (Figure has no closed-for-incompleteness records in either year).

First reason listed on Figure Lending’s denials

First denial reason2025Share of 2025 denials2024
Debt-to-income ratio7,46637.4%8,407
Credit application incomplete7,17635.9%9,516
Other2,08510.4%1,542
Credit history1,7198.6%236
Collateral1,5047.5%1,001

Debt-to-income and incomplete applications together are 73.3% of denials; collateral, the reason that dominates at some mortgage lenders, is 7.5%. The jump in credit-history denials (from 236 to 1,719) is the largest change between years, but HMDA does not carry scores, so it does not say who was refused.

Where Figure lends

Figure lent in 50 states in 2025 (49 in 2024), but its lines are concentrated: California and Florida made up 24.2% of its lines (our arithmetic). The gap to other lenders is not uniform.

Figure Lending, eight largest states by lines, 2025 (principal residence and investment property)

StateFigure linesAll lenders’ linesFigure shareFigure median rateOther lenders’ median rate
CA5,144109,2724.7%8.80%7.75%
FL2,80273,7523.8%8.75%7.50%
GA1,68433,1285.1%8.85%7.50%
OH1,52768,1792.2%8.80%7.65%
IL1,41637,6283.8%8.90%7.75%
AZ1,39032,5104.3%8.80%7.50%
NC1,18055,0592.1%10.40%6.75%
NJ1,17539,2023.0%9.40%7.40%

In North Carolina Figure’s median rate was 10.40% against 6.75% for everyone else, a gap of 3.65 points; in California it was 1.05 points. The figures say where the premium is largest, not why: state law, mix of borrowers and which banks are active all differ.

What the CFPB complaint database shows

The Consumer Financial Protection Bureau publishes consumer complaints that companies answer; the Bureau does not verify them. We queried the database on October 22, 2026. The company string is “Figure Technologies, Inc”: 284 complaints since November 2018, of which 130 are in the product category Mortgage (127 with the sub-product “Home equity loan or line of credit (HELOC)”), 100 are credit-reporting complaints and 31 are debt-collection complaints (our arithmetic).

Complaints naming Figure Technologies, Inc, by year received

YearAll productsProduct Mortgage (almost all HELOC)
2022114
2023249
20243718
20257634
2026 through October 2211555

HELOC complaints, all years: 51.2% (65 of 127) have the issue “Trouble during payment process”, 27 are about applying, 15 about closing and 12 about “Struggling to pay mortgage”; 125 were closed with an explanation, one with monetary relief and one with non-monetary relief; all 127 got a timely response. So the volume is in servicing, which fits a company that services the loans it sells. Complaints in the HELOC category rose each year (4 in 2022, 9 in 2023, 17 in 2024, 34 in 2025 and 54 in 2026 through October 22), alongside the book (servicing balance of $12.9 billion at year-end 2025 against $8.1 billion a year earlier, per the 10-K).

How does that compare? The next table divides each company’s 2025 HELOC sub-product complaints by the lines its HMDA entity originated in 2025. It is a ratio of two different populations (complaints cover each company’s whole servicing book and parent group, lines cover one year of one entity), so read it as a check on scale, not a ranking of quality.

HELOC complaints in 2025 per 10,000 lines originated in 2025

CFPB company nameHMDA entityLines originated 2025HELOC complaints 2025Per 10,000 lines
Figure Technologies, IncFigure Lending LLC33,4153410.2
NAVY FEDERAL CREDIT UNIONNavy Federal Credit Union24,9626224.8
CITIZENS FINANCIAL GROUP, INC.CITIZENS BANK, NA57,4047312.7
HUNTINGTON NATIONAL BANK, THEHuntington National Bank29,506186.1
FIFTH THIRD FINANCIAL CORPORATIONFifth Third Bank, National Association23,8862912.1
PNC Bank N.A.PNC BANK N.A.47,9617816.3
BANK OF AMERICA, NATIONAL ASSOCIATIONBank of America NA56,65312121.4
TD BANK US HOLDING COMPANYTD Bank14,4993624.8
Better Mortgage, Inc.Better Mortgage Corporation4,243921.2

Figure sits at 10.2 per 10,000, the second lowest of the nine companies in this table. 122 of Figure’s 127 HELOC complaints came through the web form.

Product mechanics from Figure’s own page

Figure’s HELOC page, captured October 22, 2026, describes two products. The fixed-rate line is “an open-end product where the full loan amount (minus the origination fee) will be 100% drawn at the time of origination”; later draws are priced at a new rate, and “the fixed rate for any additional draw may be higher than the fixed rate for the initial draw.” The variable-rate line is priced at the Wall Street Journal Prime Rate plus a stated margin, with a rate cap and floor. The page advertises “No in-person appraisal needed for loans under $400K” and a minimum of $15,000 (the maximum is a template variable on the captured page, not a number).

The consequence for a reader comparing offers is that the fixed-rate Figure line behaves like a home equity loan funded at closing, with a revolving feature added afterwards. A bank line that you draw only when needed charges interest on the drawn balance; Figure’s charges it on the full amount from the first day. The rate comparison above therefore understates the difference for a borrower who would have drawn less.

What a reader can do with this

The data above is one lender’s year. It works as a checklist, not a verdict.

  1. Price the whole line, not the headline rate. Take the amount you would actually draw, multiply by the note rate in your disclosure, and add the origination fee. On the median $65,000 line at the 2025 gap to other lenders that is about $1,040 a year in interest alone (our arithmetic).
  2. Ask how many points of CLTV you give up. Figure’s price rose with CLTV in 2025, and its rental lines almost all stayed at or below 70%. If your combined loans are above that, expect a different offer or a decline.
  3. Know your first mortgage. Nine in ten Figure lines are second liens. If your first mortgage is below the market rate, a second-lien line keeps it; if not, compare a cash-out refinance, covered with 2025 federal data in our cash-out refinance on investment property page.
  4. If it is a rental, say so and ask about the title. The record shows 1,688 rental lines at no median rate premium, but with a lower leverage ceiling and a higher denial share. An LLC on title is accepted on the page; ask whether the line is consumer-purpose or business-purpose, since only 470 of Figure’s 33,415 lines were reported as business purpose.
  5. Ask who will service the loan. More than half of the 2025 lines were reported sold to credit unions, mortgage companies or finance companies, and the complaints concentrate in payment handling. Ask who sends the statement, and whether a sale to another servicer changes where you pay.
  6. Compare with the rest of the market. Our HELOC on investment property page and investment property loans guide show the other lenders and the rental-income route.

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FAQ

This is analysis of public documents, not investment, legal or tax advice. Sources: FFIEC/CFPB HMDA Data Browser loan-level files for 2025 and 2024 (Figure Lending LLC, LEI 254900UL88QFG0E40516, all actions; national 2025 file of originated open-end lines downloaded October 7, 2026; full 2025 files of 12 other lenders), Regulation C (12 CFR 1003.4) and the FFIEC LAR data fields; CFPB Consumer Complaint Database, queried October 22, 2026; Figure Technology Solutions, Inc Form 10-K for 2025 (filed March 16, 2026), Form 10-Q for June 30, 2026 (filed August 14, 2026) and Form 8-K of September 1, 2026; Figure’s HELOC and DSCR loan pages, captured October 22, 2026. We did not use Trustpilot or Better Business Bureau ratings, which block automated access.

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