I thought I've read the discussion both here and from the HMDA GIR that counteroffers that do not Originated are considered Denied and there was no other code you could consider?
You did read that here. Adam W. pointed out (correctly so) that the August 2017 final rule had some info that changed this. I had missed this previously. That's what I quoted in my last post: If someone accepts the counter-offer, then you basically start over with the counter-offered terms being a "new" application.
So I guess you are also stating that you are in agreement that since there was no property address when the Counteroffer was made and an address comes into the picture later that changes everything?
Yes. I don't see this any different than a normal prequal where the applicants find a home. Once the house is identified, it's no longer a prequal. It' a full blow HMDA application.