we have a big secondary market home loan dept.
every now and then, when a secondary market denies a home loan we counter offer a in-house variable rate loan.
Because 2 different depts are involved we have been treating it as 2 different applications, of which we have denied one and approved one - 50% denial rate (or glass half full, 50% approval rate)-
Why? - because we have two different depts and computer systems, one for secondary market and one for in-house, plus two different staffs.
Messes up our HMDA denial rates because it seems like a lot of our protected class applications go this in-house route, don't ask me why.
so we are trying to go the counter-offer route so that when they accept our in-house variable rate loan we are one for one with no denials.
how do others handle the GFE and ETIL, do you do a turndown with the counter offer on the turndown with the new disclosures attached, saying in effect "your denied if we don't hear from you, but here is the disclosures for a in-house loan that you are free to accept"
any comments would be appreciated.