Co-Signers Sign Own Set of Disclosures/Loan App?

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Question:

I have a purchase money mortgage with a non-occupant co-signer. Can both parties sign one set of disclosures and one loan application or do we need them to each sign their own set?

Answer:

While it is certainly a sound banking practice to require signatures on credit applications, the Official Interpretations of Regulation B (Section 1002.4(c), #1) state that signature(s) is (are) not necessary in cases where a written application must be taken.

What constitutes a "set of disclosures" can vary from transaction to transaction, and over time. Generally, signed receipt is not required by consumer protection regulations. For a precise answer, you will have to review the regulations applicable to the items in each "set."

Internal requirements and those of investors and other third parties may extend well beyond legal and regulatory requirements.

First published on BankersOnline.com 6/3/13