We have some confusion about the appropriate action date to report for applications that are denied on the terms requested but where we provide a counteroffer. For example, an applicant is given an Adverse Action Notice on 10/1/2014 denying their application due to Delinquent past or present credit obligations with others; but there is a counteroffer of the same loan terms with an acceptable co-signer. The applicant is given 7 days to respond to the counteroffer, expiration date is 10/8/2014. What is the action date that should be reported – 10/1/2014 or 10/8/2014?

What if the applicant responds to the counteroffer and provides a co-signer. Upon reviewing the co-signer’s credit we determine that we cannot approve the application because the co-signer has had a bankruptcy, for example. Let’s say that this is determined on 10/10/2014. Do we report the action date of the original denial on 10/1/2014 or 10/10/2014 when it was determined that even though the applicant responded to the counteroffer, we still cannot approve the application?

IMHO you denied this loan on 10/1/14.

Informing the applicant you would re-consider the loan with a co-signer is not IMO a counteroffer. You are simply informing them if they want to offer a co-signer you would reconsider the request based on the strength of the co-signer.

Thanks for the answer Dan...

If the counteroffer were for a reduced loan amount and the applicant didn't respond, would the action date be 10/1/2014 or 10/8/2014?

If the applicant responded, we proceeded with the loan, but before closing the applicant decided to obtain the loan elsewhere and expressed this on 10/14/2014, do we report the original denial with a date of 10/1/2014 or does it become an approved but not accepted on 10/14/2014?

Because non accepted counteroffers are denials for reporting purposes I would, for consistency purposes, use the date the AAN was prepared.

So would I. 10/1/14.