Complaint sub-issue: Qualified for a better loan than the one offered

For background, I have worked in the XXXX XXXX  for over 12 years, and I currently work for one of the three XXXX XXXX  ( XXXX  ), building credit scores and helping national lenders set underwriting strategies in all industries. I do not expect any special consideration with my complaint, just explaining why I have extensive knowledge of this issue compared to the average consumer. 

I have student loans serviced by XXXX since XXXX, and I was interested in a XXXX loan ( underwritten by Earnest LLC ) as those were exclusive to XXXX customers. Per the application disclosures, the best possible rate was 3.73 % for a fixed-rate loan, likely assuming the minimum loan amount of {$5000.00} and the shortest term of 5 years. 

I applied for the loan on XX/XX/XXXX, and given an interest rate of 4.3 %. This did not make sense to me as I 1 ) was applying for the lowest loan amount of {$5000.00} ; 2 ) was applying for the shortest term of 5 years ; 3 ) had an XXXX FICO score of XXXX ( from the disclosure from XXXX  ) ; my overall credit file is spotless, as reflected by the score ; and 4 ) had a debt-to-income ratio ~4 % - 5 %. 

I called XXXX on XX/XX/XXXX around XXXX XXXX. CST and spoke with a representative named XXXX, to get an explanation of why I did not qualify for the best rate when it would seem my application was generally pristine. I was told that my XXXX credit score, while excellent, still was not good enough to qualify for the best rate. I was offered a call-back from a supervisor, which I received on XX/XX/XXXX around XXXX XXXX. from XXXX. She reiterated that while XXXX was a great score and just " a few points away, '' it was still not good enough to qualify for the best rate. I was told they could not reveal the cutoff since it was proprietary, but with only a 15-point range left, that's a questionable response. 

I believe this constitutes a UDAAP violation. While I understand each lender can set various underwriting criteria, it seems highly questionable to tell a consumer who has an XXXX credit score with other low-risk application factors ( loan amount, term, DTI , etc. ) that they do not qualify for the best terms, much less an XXXX being only 15 points away from the maximum. I was given no adverse action reasons, just that " your score wasn't high enough. '' I believe this is a UDAAP violation because it should be investigated as to how many, if any consumers, could qualify for the best rate if they are supposed to have $ XXXX in student loans but also have an XXXXother high credit score ( since most consumers with a large enough loan needing to refinance would have low-to-moderate credit scores ). It should be investigated as to how many of XXXX 's applicants ever qualified for the best rates, and whether that's a reasonable percentage of all applicants, even 1 % -2 %. If the criteria is so set so high that virtually nobody can qualify, it amounts to false advertising of an interest rate that is not attainable with a reasonably qualified application like mine ( if in fact the reason for the adverse action was my credit score and not some other undisclosed factor ). 

Again, based on my decade-plus of national industry experience, I have never experienced a lender that set a best-rate-cutoff of more than maybe 800 or 820.