Click to return to BOL home page
Banker Store Read A Reg BOL Insiders Career Connect Learning Connect Bankers Information Network

   

















    Site Map

    Our Sponsors

    Home













Compliance Gurus
Lending Gurus
Security Gurus
Marketing Gurus
Technology Gurus
eBanking Gurus

Print Friendly! Email This Article! Discuss NOW!


Counteroffers and Reg B
by: Andy Zavoina, BOL Guru
BIO AND CONTACT INFO

Question: I have a question regarding the counteroffer/adverse action provisions of Reg. B. Does a change in the "terms" of credit only apply to rate, amount, loan term, or to other aspects of the transaction? For example, if we condition a mortgage loan approval on a new roof or other work requirements, does that constitute a counteroffer and would we have to provide an adverse action letter if the borrower doesn't want to perform the work and declines the loan offer?

Answer: Reg. B defines terms as (202.2 Definitions. Paragraph 2(c)(2)(v)) "interest rate, length of maturity, collateral, or amount of downpayment".

You could classify your scenario as a counteroffer based on the collateral, because it is not acceptable in its current state of repair.

This would be the safe route.

First published on BankersOnline.com 6/17/02







Home | Compliance | Lending | Operations | Security | Marketing | Technology | eBanking
BOL Archives    Privacy Policy    Important Disclaimer   Recommend This Site !   Contact Us


BankersOnline is a free service made possible by the generous support of our advertisers and sponsors. Advertisers and sponsors are not responsible for site content. Please help us keep BankersOnline FREE to all banking professionals. Support our advertisers and sponsors by clicking through to learn more about their products and services.