Skip to content
BOL Conferences
Thread Options
#178176 - 04/09/04 02:16 AM Revised Reg B Intent and Adverse Action
inquiringmind Offline
100 Club
Joined: Mar 2003
Posts: 155
Today I spoke with sr. counsel at the FRB. They affirmed that revised Reg B only requires evidence of intent. This may be accomplished by jt applicants simply signing the application or notation in file by LO that the applicants intend to apply jointly. The purpose is to prevent joint signers on the note without "some kind of evidence" in the file of the applicants intent. Concerning adverse action, counsel stated that the reasons for adverse action must be specific, but need not indicate to which applicant a reason applies. FRB would prefer such indication, but it is not required and banks WOULD NOT be cited for not doing so. Counsel said the FRB was trying to spread the word and ease the tension in the banking industry concerning these matters.

Return to Top
Lending Compliance
#178177 - 04/09/04 01:36 PM Re: Revised Reg B Intent and Adverse Action
Anonymous
Unregistered

I have to say they created A LOT of tension in the banking community. I think many of us have spent considerable time trying to determine what plan of action would satisfy the revised reg B!!! Just had to spout off!!!!!

Return to Top
#178178 - 04/09/04 01:52 PM Re: Revised Reg B Intent and Adverse Action
Cowboys Fan Online
Power Poster
Joined: Dec 2002
Posts: 4,615
SC
And let's not forget that today is the 9th!! I feel like we are going overboard on our AAN procedures because of all of the conflicting info.
_________________________

Return to Top
#178179 - 04/12/04 12:38 PM Re: Revised Reg B Intent and Adverse Action
Anonymous
Unregistered

So the FRB was aying adverse action does not need to specifically state which party caused the adverse action? So if you have multiple parties, like two guarantors, are banks indicating a name next to the reason or leaving it general? What of FACTA?

Return to Top

Moderator:  Andy_Z