Scenario:

2) We do not use of combined statement of denial/counteroffer form.

2) Counteroffer is made and not accepted by the applicant.

3) In accordance with HMDA, we report the original loan amount and "not" the counteroffer.

Because the institution does "not" provide a combined statement of denial/counteroffer, I want to confirm that the Statement of Denial should also reflect the original loan amount, coinciding with the amount reported on the HMDA loan application register.

There is no requirement to put a loan amount on an adverse action notice.