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#1885291 - 01/10/14 05:29 PM Adverse Action & Joint Intent
Combustible Offline
Diamond Poster
Joined: Dec 2008
Posts: 1,268
Customers applied for purchase of dwelling--they have different last names, but are taking title jointly. MLO used two different applications, so is that proof enough of no joint intent?

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Lending Compliance
#1885431 - 01/10/14 07:46 PM Re: Adverse Action & Joint Intent Combustible
brownbeard Offline
Member
Joined: Nov 2013
Posts: 56
I'm not sure I understand the question. Per Regulation B, you have to evidence the applicants' intent to apply jointly at the time of application. The number of actual application forms you use is irrelevant. Did your MLO ask the applicants whether they intended to apply for joint credit?

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#1885435 - 01/10/14 07:48 PM Re: Adverse Action & Joint Intent Combustible
ahou Offline
Power Poster
ahou
Joined: Aug 2002
Posts: 3,094
Joint intent means they are applying for the loan together. If they are not both applying, why would the non-applicant have an application?
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#1885572 - 01/10/14 09:43 PM Re: Adverse Action & Joint Intent Combustible
brownbeard Offline
Member
Joined: Nov 2013
Posts: 56
Well, if they didn't apply jointly, maybe they each applied individually. But without knowing further details, it's all just wild speculation. I'm just not sure in what context the original poster would be trying to prove that there wasn't joint intent.

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#1885573 - 01/10/14 09:43 PM Re: Adverse Action & Joint Intent Combustible
Combustible Offline
Diamond Poster
Joined: Dec 2008
Posts: 1,268
I'm thinking because they weren't married to each other?

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#1885581 - 01/10/14 09:50 PM Re: Adverse Action & Joint Intent Combustible
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
You don't have to be married to apply jointly. If the lender requires non-married applicants to submit seperate applications...could be a discrimination issue.

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