Counteroffer-ultimately did not accept

The original application was received on 8.11.16 to refinance their HELOC. On 8.15.16, we counteroffered to amortize the loan because of delinquencies, etc. on the HELOC and CBR. On 8.16.16 the applicants completed a new application for the amortizing loan. Ultimately the loan was approved but the customer on 10.17.16 the customer decided not to accept the loan and obtained a VA loan instead.

Ordinarily if a counteroffer isn't ultimately accepted and originated, then the original decline stands with regards to HMDA and since HELOCs aren't reportable, we would not report it. But since the applicant completed another application on 8.16.16 for the amortizing loan (HMDA reportable loan), should we report it as approved not accepted?

The borrower completing the additional application was most likely required by your financial institution for documentation purposes. Technically it was not necessary to complete the counteroffer when all you had to do was amend the existing application.

You have a denial.

Thanks for the help!