Our policy and our practice is to require the guarantee of officers and directors when the borrower is a corporate entity. We generally do not evidence any joint intent in the file as we require these guarantees.

Now...let's reverse it. The business owner is applying for business credit and offers the guarantee of one of his successful businesses on this loan. We generally have our business applicants sign a joint intent form when intent needs to be in the file. So, if he had offered the guarantee of his wife, father, neighbor, whatever, I would see a joint intent form in the file with both of their sigs on it. Should I see Joe sign as sole member of ABC, LLC to evidence the intent of ABC as guarantor of Joe’s other business debt?

Our bank doesn't require the joint intent affirmation in that case. Not saying we're right or wrong, but seems to go beyond the intent of that particular section of Reg B. And - once again - I'd be willing to make a bet that different regulators/different examiners would give varying opinions to that scenario...

If the owner applied for a loan in their name offering a guarantee by one of their corporations at the time of application would be applying for joint credit (both the owner and the corporation meets the definition of an applicant/person) and the intent would be required.