Needing to request information relating to denial of credit application for HELOC. The Notice of Action Taken listed denial reason as "We cannot approve your request, etc.". In looking at the documentation from the loan officer, there were notes unable to verify income and unable to obtain tax returns. If this were the case, should we have denied based on unable to verify income? Or should this have been a notice of incomplete since we were could not get copies of tax returns? It was discovered later the reason we were unable to get tax returns as applicants are not U.S. citizens and would not have to file.

Thank you.

In my opinion, it would be enough to use the reason that you are unable to verify the income. If the income that they stated on their application meets your DTI guidelines then you can't tell them that it isn't enough unless you have verified their income and it wasn't enough.

You can also deny an applicant because the application is incomplete.