Counteroffers - Any time you approve an application but offer the applicant a term or terms different from those the applicant requested, you have made a counteroffer.
• If your counteroffer is accepted within 90 days of making the counteroffer, you are not required to do anything other than make the loan.
• If, however, the applicant refuses the counteroffer, then the application is treated as if it had been denied and you must send an adverse action notice… within 90 days of the counteroffer.
• Preferred method - There is an alternative available that will eliminate the need for the 90-day follow-up. This notice combines elements of the adverse action along with a description of the counteroffer you are making. Using the combined notice eliminates the need to track the 90-day period -- a lender simply sends the notice and can forget about it unless you hear back from the applicant.
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Michelle CRCM
"What would you attempt to do if you knew you could not fail?" ~ unknown