Using Counteroffers and Denials Effectively

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Question:

While scrubbing files, I found a loan request for a HELOC that did not close due to the house being listed for sale. We can't take collateral that is for sale. The officer started a new request with a different loan product that closed. I believe the first request should have been denied when we found out the house was listed for sale. However, it is past our 30 day window and we also have to report for HMDA. How do we handle this?

Answer:

If the loan officer told the applicant they could not approve a HELOC due to the property being for sale but countered the applicant with a different product the applicant accepted then no further action would have been necessary.

There is no requirement for a counteroffer to be made in writing.