Third Party requesting loan

An attorney asks one of the Bank's executive officers and then asked a lending officer about making a loan to one of the attorney's customers. The Bank has not talked to the actual customer. The bank is not interested in making a loan to the customer of the attorney. Would that require an Adverse Action Notice?

It depends - was the applicant denied or was the attorney told that you don't do third party deals and that the applicant needs to apply themselves? If the applcant was denied based on the representations of their attorney, then I would proceed with your adverse action process.