denials for credit score

Our company wants to deny loans for credit scores that fall below a minimum score requirement without going through underwriting or a fair lending second review. Is this a problem?

Depends how you are arriving at that number.

If you are just choosing a number out of the air, problem.

If you have data relating to your loan portfolio that it has experienced a higher degree of delinquencies or losses on borrowers with scores of X or below, no problem. You will however at least every 18 months (I think it is) have to re-validate your data.