On Denials, does any one have policy of 2nd review on all denials by a senior loan officer before sending denial?

We have a secondary review before mailing. The staff drew straws and compliance got the shortest one, so I review them before mailing. Our regulators suggested this and we have implemented it.

Many banks do as part of their fair lending mitigation efforts.

Each morning, after the daily officers' meeting, the loan officers meet to discuss denials and other loan data.

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?

We do as well. The officer who initially denies the loan completes a "loan denial worksheet" containing certain data about the request. He/she signs it and then submits to another (doesn't have to senior) loan officer who, if concurs, signs it also. Some of our smaller branches (where there is just one loan officer) will ask an officer at the nearest neighboring branch (sometimes is a different town) to review and sign. For consumer loans, all requests go through a central credit underwriting department. The underwriters there have another underwriter review their denials.

Every morning at the end of the loan officers' meeting, compliance officer reviews the app & AAN for compliance, while the comittee discusses the factors M Cockrell described above for fair lending. (Our compliance off is a part of the loan comittee.) Also discuss whether or not disclosures where sent already (if needed).