Reporting counteroffers

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Question:

A counteroffer was made, the borrower accepted the counteroffer, and the loan moved forward to closing, but the borrower did not sign the documents at closing and the loan was not originated. Should this application be reported with the original requested values as an Approved Not Accepted, or should we report the counteroffer values as a Denial?

Answer:

Since this application made it all the way to closing, it seems all conditions were met. This will be reported as approved not accepted using the counteroffered terms.

Refer to comments for Sec. 1003.4(a)(8)(i).

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