Reply To: denial and counteroffer

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The best way to handle it is send the counteroffer notice (Model form C-4 in Appendix C of Reg. B) which details the terms of the counteroffer and includes the adverse action notice if the applicant doesn’t accept the counteroffer. By utilizing this form, it would be acceptable to move forward with the transaction, once the counteroffer is accepted, and report the transaction as an origination.