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Adverse Act. Notice of Denial/Counteroffer Denial

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What are the requirements if a written adverse action notice of denial is provided to the applicant with a counteroffer and then the counteroffer is denied later on during the process of the application? Is the creditor required to send another adverse action notice denying the counteroffer?

If the applicant accepted the counteroffer, you have a "reset" of the application. If you later deny the new (counteroffer) request, then you owe them a denial.

If they didn't accept your counteroffer, you must tell them why you denied their original request.

Either way, you owe them a denial.

First published on 05/06/2018

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