I am looking at a denial for a refi on a primary residence and the reason given was that the credit score is too low to sell loan in the secondary market. The credit report shows collections and slow pays. I say the reasons should have been collections and slow pays but management feels the credit score reason is good enough. Any thoughts???

1002.9(b)(2) Statement of specific reasons. The statement of reasons for adverse action required by paragraph (a)(2)(i) of this section must be specific and indicate the principal reason(s) for the adverse action. Statements that the adverse action was based on the creditor's internal standards or policies or that the applicant, joint applicant, or similar party failed to achieve a qualifying score on the creditor's credit scoring system are insufficient.

Thanks rlcarey.