Is an adverse action letter required when a counter offer is accepted?
Answer by Andy Zavoina, BOL Guru BIO AND CONTACT INFO
Question: I know it is necessary to issue an ECOA Adverse Action Letter if an applicant does not accept a counter offer. I also know that Reg B allows an applicant up to 90 days to accept the counter offer. My question is this - If an applicant ACCEPTS the counter offer, is an Adverse Action letter required for the original request?
Answer: If a counteroffer is accepted no adverse action notice is necessary.
The 90 days you mention may be the time in which a counteroffer is allowed to remain on the table before an adverse action notice is required to be delivered. There is no mandatory time-frame in which a counteroffer must remain.
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