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ECOA Credit Discrimination on Joint Account

Answered by: 
Dan Persfull

Question: 
The ECOA came out last year stating that creditors cannot discriminate on the handling of credit report fees on the basis of marriage. The two companies that we pull credit reports from do not charge differently if we pull a single report or a joint report. Where we think that we see a possible concern when we have 3 borrowers on a loan (2 married and 1 parent). The parent will be charged the same as the joint children. Is this a potential discrimination? Please clarify for us when an application is really considered a joint application. Is there any guidance out there? When should we be using 1 application verses 2 applications or 2 verses 1? Any guidance would be greatly appreciated.
Answer: 

Please clarify for us when an application is really considered a joint application. -- Under Reg B joint intent is required to be established at the time of application.

Joint credit is when the applicants apply contemporaneously for the requested credit.

Is there any guidance out there?

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David has been teaching this topic for years and his knowledge and expertise will be of great benefit to you and your institution.

First published on BankersOnline.com 6/27/11

First published on 06/27/2011

Filed under: 
Lending
Filed under lending as: 
Applications
Credit Report
Discrimination
ECOA
Fees

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