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hi my name is adam whitmer im the founder and host here compliancecohort.com this compliance clip is going to discuss whether an adverse action notice is required for a withdrawn counter offer on a business commercial loan so the question we have here says upon receiving an application for a commercial loan to a business entity the loan officer verbally countered offered but the applicant denied and wanted to withdraw their application does this application need an adverse action notice and if so what are the decline reasons that we need to give the customer so this is our question and our answer of course is going to come from regulation b its going to come from two parts to regulation b its going to come from 1002.2 which is our definition section of regulation b as well as 100 2.9 which is the portion of regulation b that talks about adverse action notices and specifically 100 2.9 a 3. so lets take a look at these parts of regulation b first of all 102.2 the definition section o