After 5 months of underwriting review, my refinancing loan was denied right before rate-lock expiration. Loan processor represented that the underwriter (an outsourced 3rd party company hired by Bank of America/Merrill Lynch mortgage) gave the following reasons: 1. Appraised value was too low ( in response, I submitted 4 additional sold comps to support the higher value to satisfy the LTV requirements) 2. W2 Income came from multiple sources thus only one employer income qualifies to calculate Income-to-Debt Ratio (in response, I showed 4 years of W2 income indicating the same income trends ) 3. Interest/dividend income cannot be included unless it is guaranteed for 3 years (in response, I showed 3 months of interest/dividends received and confirmation from brokerage firm that investments have a projected ROI, but no investment returns can be "guaranteed" for 3 years). Despite my efforts to provide all documentation, it appears that the bank has made a foregone decision not to honor the refinancing with the attractive interest rate offered 5 months ago. I believe the bank had to intention to close the deal and was finding excuses to deny. Is this legal, ethical?