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Reply To: Counteroffer to HMDA??

Home Forums Home Mortgage Disclosure Act Counteroffer to HMDA?? Reply To: Counteroffer to HMDA??

#12047

rcooper
Keymaster

In my opinion, you base the action on the original application. The counteroffer was not accepted so what you are left with was the original app. Although Reg C didn’t apply to the original app, I think Reg C commentary does support the general idea of looking to the original app when a counteroffer is not accepted (see paragraph 4(8)(a) discussing action taken).