Reg B Joint Credit 90 Day Extension

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Question:

Does the Joint Credit under Regulation B applies to a 90 day extension of an existing loan? We are only extending the maturity date to allowed additional time to analysis and review.

Answer:

Technically, yes. The original application was not for what this request represents. The multiple parties applied for a loan that was to mature before the extension. You have documentation indicated this is what they wanted. Now, there's a change to the original request (triggering the extension). Do all parties agree to this new arrangement?

With that said, most institutions don't get joint intent documentation on short extensions and it doesn't seem to get cited, in my experience. It's your risk decision.