We are trying to find a way to indicate joint intent for commercial and agricultural loans. Our loan department doesn't want to implement apps.

Would it be acceptable to have a box on the financial statement indicating if it is individual or joint credit and if joint then a place to intial that they intend to apply for joint credit?

That is what we did. We added a section to our Personal Financial Statement for the customers to indicate their intent to apply jointly.

FYI, the examiners I've encountered will not accept the joint intent statement on the PFS as signifying the Reg B joint intent requirement for a particular loan. Part of this is because PFS's are often time reused and copied from file to file for subsequent loan requsts. Reg B is extremely clear that joint intent has to be documented at the time of application.

I agree with the Anonymous above me. The regulation specifically says a personal financial statement that indicates joint intent cannot be used.

Here's what I was looking for (taken from Reg B):

d) Signature of spouse or other person—(1) Rule for qualified applicant. Except as provided in this paragraph, a creditor shall not require the signature of an applicant’s spouse or other person, other than a joint applicant, on any credit instrument if the applicant qualifies under the creditor’s standards of creditworthiness for the amount and terms of the credit requested. A creditor shall not deem the submission of a joint financial statement or other evidence of jointly held assets as an application for joint credit.

I think that means that you can't just use the joint PFS as proof as intent to file jointly. I think adding a statement regarding intent to file jointly with required signatures and date it is a different beast. With that being said, we use a separate form for commercial customers to evidence intent to apply jointly.

I think adding a statement regarding intent to file jointly with required signatures and date it is a different beast.

If I was to remotely consider this route I would make sure the font was bold, italic and twice the size of any other font on the FS and to specifically highlight THIS IS TO CERTIFY OUR INTENT TO APPLY FOR JOINT CREDIT. Most people will just see it as they are submitting a joint financial statement if the section is not made to stand out.

And I also agree with the second Anon. If you go this route then you will have to have the applicants complete a FS for each credit request or you will have to have them certify, at the time of application, they are applying for joint credit with the new credit request.



When the new GMI collection requirements come down you are going to have to develop some sort of app or form to collect all the required information for small businesses, women owned business and minority owned businesses.

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Our loan department doesn't want to implement apps.

If you are adding a joint intent statement to the financial statement - I'll give you one guess what you have...... wait, wait........You got it!! An application!!!

Dan is correct, tell these people it is time to boldly step into the 21st Century.

Response from business lending when asking about the application process:

"You can't expect a business owner to fill out an application. Nobody does that!"

Response from business lending support staff when asking about tracking of denial of business credit:

"We don't assign loan numbers until the loan is approved. For denied files we can track them if we can get the LO to not throw the file away."

I have heard this excuse more than once. The truth is that business owners will do whatever you ask them to do. They may push back at first, especially if they are used to pushing your lenders around, but in the end, they want the loan and a bit of paperwork is not going to kill the deal 99% of the time. Have your lenders type it up and it takes the customer 2 seconds to sign it. If you still get push back, you know the issue is not about upset customers; the issue is about lender who don't want to do extra work.

The last time I heard this excuse, the Bank ended up with MAJOR CMPs for HMDA, party due to the lack of data collection on business loans. There are many reasons why an application is LOGISTICALLY a good idea.

I agree AJ, it is not a valid statement. If I had a dollar...

Just because you call something an "application form" doesn't mean it has to be lengthy or complex. A commercial application form can be a simple summary of the business' exact corporate identity, a description of the credit requested, some indication of the collateral and personal guarantees offered, contact information, and the date the credit request was made. You could fit this much information on the back of a business card. Financial statements (hopefully audited) will provide the detail your analysts need to make a credit decision.

Or, if they could just see things from our side of the desk. Most of us have been in their shoes at one time or another...