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#12117

KRT
Participant

Can you clarify please? What is the best way to handle these situations? Should the original loan application be denied and a new application started? Or, is it also acceptable to provide a combined Adverse Action Notice with Counteroffer, where the husband’s notice shows his credit reasons with a counteroffer to make the loan in the wife’s name only, and the wife’s notice shows co-borrower credit as the reason with a counteroffer to make the loan in her name only? If we provide them with a combined adverse action/counteroffer notice, is it acceptable to continue the transaction with the original application and report the transaction as an origination?