Officer denied applicant for have delinquent past or present credit. When I look at the credit report, all of the unpaid appear to be medical based on what the credit reporting agency has told me. Can we get into trouble if we based a denial solely on medical debt?

What does your loan/underwriting policy say, and do you look at it the same way for all applicants?

You are not allowed to treat medical debt any different that any other debt. As long as anyone that applies with that same credit history would get denied, there is not a problem.

Many lenders do treat medical debt differently than other debts. It depends on what your credit policy says.

A CFPB study found that medical debt excessively penalizes consumers relative to other debt. http://files.consumerfinance.gov/f/201405_cfpb_report_data-point_medical-debt-credit-scores.pdf

The major credit bureaus have also changed how they treat medical debt and related disputes. http://www.cdiaonline.org/ConsumerInfo/content.cfm?ItemNumber=11156

Many lenders do treat medical debt differently than other debts.

Hopefully not less favorably in violation of the FCRA:

The creditor uses the medical information in a manner and to an extent that is no less favorable than it would use comparable information that is not medical information in a credit transaction; and