Is requiring co-borrower a denial?

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Question:

I saw a post on the BOL website from 2018 by David Dickinson titled "Applicant Re-Apply w/Co-Borrower: Counteroffer?" It was unclear to me whether the lender's requirement to add a co-borrower constitutes an "other term" as part of a "counteroffer" or whether the requirement to add a co-borrower requires the denial and written adverse action of the borrower and a new application by the borrower and co-borrower (i.e. is requiring a co borrower really a counter offer). I would appreciate any clarification on the issue.

Answer:

You would either send them an adverse action notice combined with the counteroffer to make them a loan if they can provide a qualified co-borrower, or you provide them the counteroffer and then give them an adverse action notice if the customer does not accept the counteroffer within 90 days. Refer to 1002.9(a)(1) and Comments 5 and 6 to that section: https://www.bankersonline.com/regulations/12-1002-009