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Adverse Act. Notice of Denial/Counteroffer Denial

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Question: 
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?
Answer: 

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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