Counteroffer Provisions
Question: We have been discussing the adverse action notices and have a concern about the counteroffer provisions. If we make a counteroffer but do not give the applicant the reasons for adverse action and the applicant rejects the counteroffer, we must send the adverse action notice within 90 days. Do we have to keep the counteroffer open for those 90 days?
Answer: No. You can - and should - specify a time period for the counteroffer. Regulation B does not specify any specific time period. Most lenders use 30 or 60 days. Select a time period that is realistic for the rate and terms offered. Be sure, however, to give the customer time to consider the offer and respond. That's just fair play.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 12, 11/04
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