Separate Loan Apps for Unmarried Co-borrowers?
Answer by Dan Persfull, BOL Guru Guru Bio
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.
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