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Intent to apply for joint credit

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Question: 
In reviewing our Consumer Loan Application, I noticed there is no formal Reg B section in which the Borrower(s) indicate whether they are applying for individual credit or joint credit. In my prior employment, the applications always included a formal Reg B section. Is this formal section required?
Answer: 

No. Those are model forms and it is not mandatory to use them. Many banks use a separate form for the applicant to complete indicating their intent.

3. Evidence of joint application. A person's intent to be a joint applicant must be evidenced at the time of application. Signatures on a promissory note may not be used to show intent to apply for joint credit. On the other hand, signatures or initials on a credit application affirming applicants' intent to apply for joint credit may be used to establish intent to apply for joint credit. (See Appendix B.) The method used to establish intent must be distinct from the means used by individuals to affirm the accuracy of information. For example, signatures on a joint financial statement affirming the veracity of information are not sufficient to establish intent to apply for joint credit.

First published on 07/21/2024

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