Separate Loan Apps for Unmarried Co-borrowers?

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Question:

Someone in our holding company's compliance area told us that unmarried co-borrowers should complete separate loan applications when applying for joint credit. I've reviewed both the WBA-FIPCO forms and the Wolters Kluwer Financial Services ARTA Lending forms and they appear to allow unmarried co-borrowers to be on the same loan application. Can you give me any regulatory guidance here?

Answer:

Start off by referring to the prohibitive basis in Reg B which you will find one of them to be marital status. Requiring unmarried joint applicants to complete separate applications is treating applicants differently based on their marital status.

First published on BankersOnline.com 7/14/08