Rejected Counteroffer

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Question:

A customer applied for a HELOC and the Bank decides not to approve them due to their declining financial condition and offered a closed end home equity loan. The customer declined the offer, paid off the HELOC and went elsewhere. Is an Adverse Action Notice required?

Answer:

The Bank made the customer a counteroffer which the customer declined. If you provided the counteroffer verbally, an Adverse Action Notice must be provided. If you provided the customer with a combined Counteroffer/Adverse Action Notice, an additional Notice is not required.
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Adverse Action Notice Requirements - Staying Compliant When Saying No webinar.