AA Notice Required if Counteroffer Not Accepted?

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Question:

I know that adverse action notices are required on indirect lending contracts we deny, but are Adverse Action notices required when we submit a counteroffer that is not accepted?

Answer:

If the bank issued a combined counteroffer/adverse action notice as allowed under Reg B, no additional notice is required. If the combined notice was not issued, then a separate adverse action notice is needed. Form C-4 in Appendix C to Regulation B is an example of a combined counteroffer/adverse action notice.

First published on BankersOnline.com 6/10/13