Okay, I know that numerous folks have posted on the topic of Regulation B changes, but I need to raise it yet again. The question is this: since we do not require applicants to complete a written application, what type of evidence will we have to produce to show our joint borrowers intended to apply jointly? Will it be sufficient to send a confirmation letter to both borrowers at the time we book the card (or an adverse action notice to both applicants when we reject the application)? Is there any other way we can get around having to have both applicants sign that they intend to apply jointly? I'd appreciate any help from anyone!

The evidence that joint borrowers intended to apply jointly needs to be documented at the application-stage, so I wouldn't think that a confirmation letter sent when the account is booked would work.

It's crazy. There is no requirement that we obtain a written application for credit cards, but apparently we have to obtain a written statement from the applicants indicating that they wish to apply jointly. Crazy.

Our government at work