As Randy said, this is a denial that requires a Notice of Action Taken (NAT) as you have refused to grant credit on substantially the same terms they applied for. If they had expressly accepted or used your counter offer of a higher rate, it would be no harm no foul (no NAT needed). However, when they don't expressly accept or use a counter offer, your application defaults to what they applied for, meaning you are denying them.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com