[mdunker]

We have a loan in which the appraisal came in higher than expected and the customer whishes to increase their loan amount, however since the time of application rates have increased. We will approve this requested but will require the higher rate. Is this a counter offer?

[rcooper]

I would consider this a counteroffer because the applicant has requested an additional amount based on the same rate, but you are not able to offer the new amount at that rate. As a result, you will be countering their request with a higher rate. I believe you would also have a changed circumstance (borrower requested change) and a new LE would be required. Note if the applicant does not accept the counteroffer then a adverse action would be required if it was not included with the counteroffer.

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