[kvet18]

How do you interpret the following excerpt from Reg B section 1002.2? Do you interpret (or know of any guidance) this to mean that a creditor can determine what is “not substantial” and therefore not issue a denial/counteroffer letter? If so, are there any guidelines out there as to what “substantial” or “not substantial” are defined as?
(i) A refusal to grant credit in substantially the amount or on substantially the terms requested in an application unless the creditor makes a counteroffer (to grant credit in a different amount or on other terms) and the applicant uses or expressly accepts the credit offered.

[rcooper]

I am not aware of any guidance that defines “substantial”. I would be hesitant to allow a lender to determine what is and is not substantial. My opinion has always been if we are not granting credit in the amount or for the terms requested then a denial or counteroffer would come into play.

[Author]

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