Reg B Commentary states that a creditor does not have to hold a counteroffer open for any particular length of time. Has anyone been criticized by the examiners for sending the a/a notice after a counteroffer too soon? We would like to keep the timeframe the same as our regular denial process and use the w/in 30 day timeframe. Does anyone see any problems with that?

I think 30 days is sufficient, and, in fact, you are being nice. We give our applicants 5 days to accept a counter offer.

30 days is more than sufficient. It is almost too much time and you may need to verify debts with the customer again if they do come in at the tail end of that as they could be borrowing elsewhere in the interim and distorting their debt ratio. Allowing mail time, 10 days is generally more than enough IMHO.