Should we get the joint form on renewals or just new loans?

Confused

If you are asking about the form to document those applicants who are applying jointly, it is needed for all loans.

I think it depends who your regulator is. We are an FDIC bank and based on discussions with them and our state banking association, they are not requiring the intent for joint application on renewals, only new loan requests and refinances.

Same here. Since the regulation is based on intent to APPLY if you have no new application you shouldn't require an intent to apply.

Is this the same FDIC that says the 1003 is not sufficient ? What a mess !

I think it is required because of the similarity with 202.7 (commentary on renewals)
If the borrower's creditworthiness is reevalauated when a credit obligation is renewed the creditor must determine whether an additional party is still warranted and, if not warranted, release the additional party.