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#1778104 - 01/18/13 07:56 PM Counter Offer then Denial
3up3down Offline
Junior Member
Joined: Jun 2008
Posts: 25
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?

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#1778145 - 01/18/13 08:42 PM Re: Counter Offer then Denial 3up3down
ComplianceNerd Offline
Gold Star
Joined: Nov 2011
Posts: 376
Texas ...
Depends on what your denial reasons are.
Per FCRA, you need two. Per Reg. B you could be ok with one.

Need more info.
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Can't is not an option.

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#1778223 - 01/18/13 09:56 PM Re: Counter Offer then Denial ComplianceNerd
3up3down Offline
Junior Member
Joined: Jun 2008
Posts: 25
Income Insufficient for Amount of Credit Requested
and
Excessive Obligations in Relation to Income

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#1778338 - 01/21/13 04:33 PM Re: Counter Offer then Denial 3up3down
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,832
Bloomington, IN
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 datereinstated 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?
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The opinions expressed are mine and they are not to be taken as legal advice.

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