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.