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#1787252 - 02/19/13 05:10 PM Credit Offer for less than the Requested Amount
MikeD Offline
Junior Member
Joined: Jul 2004
Posts: 30
Los Angeles
Sorry to ask a dumb question like this, but I'd love to get a complete clarificaton on this issue. We're a small loan company. Customer requests $5000 loan, we offer $4000 loan, based on collateral not credit, customer refuses for one reason or another (maybe rate, maybe amount). Does this constitute a turndown such that an ECOA letter should be sent? Thanks for indulging me here.

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#1787292 - 02/19/13 06:40 PM Re: Credit Offer for less than the Requested Amount MikeD
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,962
Bloomington, IN
An unaccepted counteroffer is a denial on the original terms requested and would require the ECOA AAN and the FCRA AAN if a consumer report had a part in the adverse action.
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The opinions expressed are mine and they are not to be taken as legal advice.

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