we code as HI so that isn't the question.
HI secured by cash out on auto.
Original request $12000. We countered with $8000.
They accepted. Before we get loan documents signed, the auto is totaled.
Code as ??
They put a 2 - approved but not accepted but I don't think that is correct. And which $ amount do I use?
Thoughts are appreciated.

Code as denied. They didn't accept the counteroffer, as the loan didn't consummate.

Oh....use the original amount: $12,000.

Basically, once you extend a counteroffer, "approved not accepted" is off the table. Either you'll code it as "loan originated" if it originates; or "denied", if it doesn't.

HMDA GIR

Paragraph 4(a)(8).
1.
Action taken—counteroffers. If an institution makes a counteroffer to lend on terms different from the applicant’s initial request (for example, for a shorter loan maturity or in a different amount) and the applicant does not accept the counteroffer or fails to respond, the institution reports the action taken as a denial on the original terms requested by the applicant.

I agree with you RJ; because the original requested amount and terms were not approved, and there wasn't an origination, this is a denial for $12,000.

Thank you