Have a weird situation on my hands. We received an application for refi back in February that ended up being denied in April due to credit history. However, it looks like we made a counter offer in May that ended up being originated. In my mind, that is two different files, and both the denial and origination should be reported. Thoughts?

If they accepted a counter offer, why would this be two separate applications?

I say counter offer, but I don't know that we formally made a counter; I am waiting to hear back from the LO. Assuming there was not a counter offer and being a month apart, how should I go about this?

From the GIR. Your option:

3. Application date—reinstated application. If, within the same calendar year, an applicant asks an institution to reinstate a counteroffer that the applicant previously did not accept (or asks the institution to reconsider an application that was denied, withdrawn, or closed for incompleteness), the institution may treat that request as the continuation of the earlier transaction or as a new transaction. If the institution treats the request for reinstatement or reconsideration as a new transaction, it reports the date of the request as the application date.

Thank you sir! So, to clarify, IF we choose to treat it as a new transaction, then we report both denial and new transaction. However, IF we choose to treat as a reinstatement/continuation, then we just report once using the original application date.

You got it