Personal Loan & Applicant without Credit

My bank offers consumer personal loans, and we recently hired a new underwriter for mortgage and consumer loans. Our new underwriter is saying that if the applicant shows no credit (no trade lines) from all 3 bureaus we must ask the applicant to supply us with four non-credit payment references. I know we have done this in the past for mortgages as we underwrite to Freddie Mac policies and this is one of their requirements to establish credit, but is this something that should be done for personal loans as well? We have never done this in the past.