[Kristin]

If we receive an application for a purchase loan:
Purchase price $200,000 with a loan amount of $160,000 but the appraisal comes back at $190,000 therefore changing purchase price to $190,000 and loan amount to $152,000 can this just be treated as a changed circumstance or do we need to send a denial/counteroffer letter or both? Where can we draw the line or is there even a line to draw since each comes from a different regulation?

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[rcooper]

Per Regulation B, I would issue a counteroffer and since this would be considered a changed circumstance, also issue a revised GFE per the those rules.

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