Unmarried Co-Applicants

Question: With the changes to Regulation B and recent discussions, we are still confused about how to aggregate income for unmarried co-borrowers. Can you clear this up for us?

Answer: The simplest rule to follow is to apply the same procedures to unmarried co-applicants that you use for married co-applicants. Thus, if you combine the income and the debts of married applicants, you should combine the income and the debt of unmarried co-applicants. Bear in mind that the results may be different because married co-applicants usually share most of their debt while unmarried co-applicants are more likely to have separate obligations. If, when evaluating married co-applicants, you take the larger income and compare that to the debts for which that individual is liable, then you could do the same for unmarried co-applicants. We do have one word of caution: when it comes to Regulation B, the test is what you actually do, not simply what you say you do or what you sometimes do.

Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 11, 10/04