CGD, IMHO, your 2nd review can possibly be improved. The bank is only confirming that the loan was denied for legitimate purposes. What it does not do is to identify if other similarly situated applicants were approved. That is what regulators look for in a comparative file review.
One way is for a senior credit review officer (like yours) to look at the application and to try and identify if a loan was approved to a similarly situated applicant. Loan officers have different skill sets, experiences and authorities, and you are looking to see if the BANK is making similar decisions on all applications.
Integrity. With it, nothing else matters. Without it, nothing else matters.