10/4/12-Application Received for Borrower who offered co-signer, if needed

10/9/12- Counter Offer sent that said, “Would consider with qualified co-signer”

10/12/12- Received application on co-signer

11/5/12 – Application Denied

Do I report both borrowers in one entry or would I technically have two denials?

Depends on what your denial reasons are.
Per FCRA, you need two. Per Reg. B you could be ok with one.

Need more info.

Income Insufficient for Amount of Credit Requested
and
Excessive Obligations in Relation to Income

Based on the original post there was no counteroffer. They simply told the applicant they can't make the loan as applied for but they would reconsider the request with a co-signer.

If the applicant produced a co-signer for consideration then they reinstated their application and the FI has an option how they report. See Application date—reinstated application on page D-9 of the GIR.


Depends on what your denial reasons are.
Per FCRA, you need two.

Where in the FCRA does it mandate 2 denial reasons?