Reg B

If we make a counter-offer...how long do we have to give the applicant to respond? 30 or 45 days?

As long as you want. You should list a date on the counter-offer notice.

Keep in mind that your counter-offer is based in part on the DU findings. They have an expiration date beyond which your counter-offer will no longer be valid anyway.

Don't forget.....if you don't use the combined counter-offer/denial notice, and the applicant hasn't responded to the counter-offer within 30 days of the date the ap was received, you'll need to send an official denial notice.

We DO use the combined counter-offer/denial notice. We give the borrower 30 days to respond and if they do not, we send another notice denying the request.

Just wanted to make sure this is the right way to go about it.

If you are using the combined notice then there is no need to follow up with another AAN if the applicant does not contact you by the date specified on the combined notice.