[quote] reporting it as an approved but not accepted is the correct way to report this.
Couldn't this also be treated as a denial? What if the reason that the applicant went to a different bank is that we offered him 9%, and the other bank offered him 8%? Wouldn't that be refusal to "grant credit on the terms requested," thus triggering an adverse action notice under ECOA? In cases where we know that the reason for "approved but not accepted" has something to do with the terms of credit offered, we treat it as a denial. We send a combination denail-counteroffer letter, stating, "unable to provide what you requested, but, we can offer you the loan for X months at 9%." Is that wrong?
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