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Unanswered Email a Counteroffer or Withdrawal?

Answered by: 
John Burnett

Question: 
When a consumer real estate application is received via the internet (website) and is for a term, LTV, etc., other than what we offer, we send an e-mail explaining this. If the customer does not respond, do we treat this as a counter offer for Reg B and HMDA? Or as a withdrawal for these?
Answer: 

Because of the non-secure nature of email, I trust that your message is given in the most general of terms. And that probably means you are not telling the applicant that you are approving the application but on terms differing from those requested. Instead, you are probably telling the applicant that you don't offer mortgages of the type, term, etc., that is requested. I don't believe you are making a counteroffer, therefore.

I think you treat the application as denied.

First published on BankersOnline.com 11/21/05

First published on 11/21/2005

Filed under: 
Technology
Filed under technology as: 
Estate
Internet

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