I need help with an adverse action reason.
Consumers applied for 15 year unsecured home improvement loan. Loan policy states we can only offer unsecured loans for a period of 3 years. Would like to counteroffer but need a denial reason to put on form. Everything I read online says that reasons like bank does not offer or does not fit bank policy are too vague and not adequate. The borrower has high credit scores with no late pays and the only reason I can think to deny this is a debt to income of 51%.
Does anyone have any advice on this?
Also looking for resouces/help for adverse action notices.
Thanks!

I've never had an examiner object to "the bank does not offer" as a denial reason (or objected to it when I was an examiner), as long as it was true. If you don't offer the product, you don't offer the product. In your situation you may want to specify that you don't offer 15 year term but you do offer 3 year terms. "Doesn't fit bank policy" is too vague as you would need to specify what bank policy (LTV, collateral, etc.).

Others may have different experiences and advice, but I don’t have any problem defending “bank doesn’t offer” as a denial reason (although it is often used incorrectly, which is a different situation).