Providing Early TIL on Counteroffers

Compliance > Regulation Z - TILA
If the lender provides the borrower with a counteroffer, do the 7 and 3 day time periods to close the loan begin again?

The Federal Reserve has not issued written guidance on this.  However, it has indicated orally that the first early TIL that was provided will begin the 7-day clock, even if a counteroffer is subsequently provided.  Likewise, the 3-day time period to close the loan after a revised early TIL was received by the borrower does not begin again simply because a counteroffer was provided to the borrower (though a revised early TIL may be required based on the terms of the counteroffer, resulting in a new 3-day time period beginning).

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