If a customer applies for a fixed rate secondary market product, they don't qualify (i.e. appraisal issues with investor), and you send a written counter-offer for an in-house ARM product, do you need to send the ARM program disclosure with that counteroffer letter? I think you do, but others say you don't unless the customer decides to accept the counteroffer (and, they've never been written up for not doing this).

Thank you!

I would include it for the applicant to be able to review the terms of the ARM in order for them to make an informed decision whether they wanted to apply for the ARM.

However, I agree with those that say it is not necessary (required) until the applicant actually accepts the invitation and applies for the ARM.

Thank you, Dan!