Standalone Counteroffer Letter - need FCRA ?

Does a standalone counteroffer letter require the FCRA disclosures with credit score information? We have a 2-step process - if the counteroffer is not accepted by the deadline, we send an adverse action notice with the FCRA disclosures.

So, here's what I’m thinking. The standalone counteroffer letter is not required to be in writing therefore it can be anything we want it to be. And it does not have to include the credit score (FCRA) information – since we will send a separate Adverse Action Notice (AAN) if not accepted. If the customer accepts the counteroffer, we have not taken adverse action and we make the loan. If they reject the counteroffer, we send the AAN with the reasons why their original request was denied – and include the FCRA & ECOA disclosures. We have the 2-step process. Does this sound correct?