According to our policy, denied and withdrawn loans should be forwarded to Credit Review Officer for 2nd review. During the 2nd review, he basically looks at the reason for the denial on the AAN, and determine the reason was a valid one, or whether the denial is premature or improper. And the only evidence is his signature on the AAN.

Deos any of you use 2nd review checklist for it, or if a signature is okay to believe that the 2nd review was conducted.

I appreciate your support in this.

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.

Even if your second review process does not use the approach that Rocky suggested, your fair lending testing should. Many companies separate these two parts of the review.