What is the best way to handle Jt Unmarried Applicants who want their info kept seperate. (ie Step Dad signing with Step Son). Should we make them sign a Joint App or complete seperate apps as requested by the Borrowers to Protect their "Privacy". I know there is Reg B commentary that states that Jt Applicants wave their right to Privacy by applying jointly.

As you stated, there is no privacy between joint applicants. They can complete separate applications, but you must document their intent to apply jointly. If you deny them, the primary applicant MUST receive ALL reasons for denial (including the reasons that apply to the co-applicant).

Thanks for the confirmation. Do you know where I can find specific commentary to support my positon? When I stated I knew there was commentary, it was aways "verbal", but I can't find physical commentary.

From the preamble to the March 2003 amendments to Regulation B:

9(b)(2) Statement of specific reasons

Section 202.9(b)(2), adopted as proposed, clarifies that whether a creditor’s denial of credit is based on the creditworthiness of the applicant, a joint applicant, or guarantor, the reasons for adverse action must be specific. For example, a general statement that “the guarantor did not meet the creditor’s standards of creditworthiness” is insufficient.

The legislative history of the requirement to provide specific reasons for adverse action indicates that the purposes of the disclosure are to help achieve the antidiscrimination goals of the ECOA and to educate and inform consumers. These dual purposes are served by the clarification in § 202.9(b)(2). For example, the disclosure may discourage a creditor from discriminating based on a co-applicant’s or guarantor’s race, sex, age, or other prohibited basis. Also, the disclosure may help educate and inform applicants, co-applicants, or guarantors as to reasons for denial that are not apparent from looking at their credit report.

Many commenters were concerned about the co-applicant’s or guarantor’s privacy when the reasons for adverse action pertaining to creditworthiness are given to the primary applicant. When a person agrees to be a co-applicant, guarantor, or similar party, however, there is (or should be) a general understanding that information will be shared. Accordingly, the rule has been adopted as proposed.