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

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Question: 
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?
Answer: 

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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