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Applicant Re-Apply w/ Co-Borrower: Counteroffer?

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If an applicant is declined for a loan but then decides to re-apply with a co-borrower is this considered a counteroffer, meaning an adverse action for the first request would not need to be sent?

If the applicant is declined, they you owe them an adverse action notice (AAN). They can't counter-offer you.

If you counter-offer them and said "if you provide an acceptable co-applicant we will reconsider" and they do, then they accepted your counter-offer and no AAN is triggered at this point.

First published on 06/10/2018

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