Yes, we do. As a matter of fact, we ask our senior officers to counsel/mentor the junior officers about denial decisions (when appropriate).
I placed the following in a PowerPoint slide for a recent training class:
2nd review (SVP or above): although technical compliance is desired, the greatest objective during the review is integrity; in other words, from a Fair Lending perspective, "
Does the denial reflect fairness and consistency in the decision-making?"
Take the time to fully
utilize this review
process to maximize the loan opportunity.Before "initialing off," ask the following questions:
- Do you concur with the decision to deny?
- Does the documentation support the decision?
- Does the documentation support the reason(s) listed on the Notice of Action Taken ("NAT")/Adverse Action Notice ("AAN")?
- Would a counteroffer be more appropriate?
- Could the app reasonably be approved within existing underwriting guidelines?