Using the philosophy behind the covered loan amount, included in your cite, and counteroffers, what did the applicant apply for? If they applied for $X and later amended it to $X+1, they are requesting $X+1. If they requested $X and the bank was offering $X-1, and the applicant never accepted that offer, they're still at $X. If they accepted that amount but then failed to follow thru of some other requirements, substantiated by documenting their approval of the counteroffer, you're at $X-1. It is the covered loan amount you're after for this.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell