Husband and wife apply jointly for a consumer loan. Wife signs application and a credit bureau is pulled. Husband never signs application. Is adverse action notice sent only to wife or should husband have one too?

Under the revised Reg B, how do you have a joint application without an affirmation of intent to apply from the husband?

If you pulled a credit report on the husband and information from that report caused you to deny the loan then you do need to provide the FCRA disclosure to him. Depending on the situation, if they both had the same credit history that led to the denial I think you could send one combined ECOA/FCRA notice and address it to both of them.

Information on the husband was filled in on the application, but he never signed it. We did not pull a credit report on him.

Then I don't believe you had a joint application.

David, I don't really disagree with your statements, but they really do need to re-evaluate what constitutes an application from an applicant. For example, if I submitted an application with you named as a co-applicant, would they process it without your signature? If they won't then they have different application procedures for married verses unmarried applicants and would run afoul of Reg B. I agree there is no requirement for written applications and even no requirement for signatures, but if the husband was truely an active participant in this loan application - why the question?