We have had a commercial loan applicant requesting $1 million+ for a development project. Upon a cursory negative news search, it was discovered that our applicant had been convicted, with four other defendants, for an elaborate $20 million dollar local mortgage fraud scheme. Our applicant individually was responsible for mortgage lenders’ losses of $1 million dollars. This information is from an FBI Press Release. My question is, in an adverse action notice, what would we cite as the denial reason? I’ve never come across this so am struggling with it a bit. I reviewed the lending manuals we have and nothing seems to apply – I really appreciate any insight you have on this situation!