Answer:
Whether you are making a counteroffer depends on what the applicant requested. If the applicant requested a $5,000 credit limit and you only offer a $2,000 line, that would be a counteroffer requiring either the counteroffer notice or an adverse action notice if the applicant did not accept the counteroffer. However, the process you describe does not appear to tell the applicant about a credit limit or ask the applicant for one. In this case, your offer is simply your offer. The fact that you use $5,000 as an internal standard is not relevant to the notification process because the customer didn't request it or even know about it.
First published on BankersOnline.com 7/12/10
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