Our loan disclosure software has a joint intent form that only has a statement "We the undersigned intend to apply for joint credit" and then a place for two signatures. It doesn't have a place for individual credit or for individual but relying on the income of someone else. Is this going to cause a problem with examiners by us not having the other two options?

Why would an individual need to sign a joint intent statement?

We stay pretty well mixed up on this to be honest. We have auditors and also find in research that it is a best practice to have applicants put that they are applying for joint or individual credit and that we should always have it documented.

Our platform system also has a separate Joint Intent statement. If you use an application with that already on it...you do not need the additional form. It works well when you need to document JI when using an application that does not contain that language, or no real formal app at all.

It's not for use, at all, for anything BUT joint credit.

Your auditors are confusing you. The only time it must be documented (per regulation) is when you have more than one borrower.

info on BOL is confusing too because a search from a BOL Guru says to document both.

The regulation only requires documentation if there is multiple applicants. However, many banks go above and beyond. Many have a procedure that is to always document intent to apply (be it joint or individual) on every request for credit. The idea then, is that the systematic practice helps mitigate (hopefully) the risk of loan officers forgetting to document when required under the regulation.

Our Commercial & Consumer applications both have the statement We intend to apply for joint credit Initial here ____ with two lines and they have to initial. Our Visa applications have a check box at the top that you mark if you want individual account or joint account and if joint account it says: see co-applicant and signature section below. co-applicant section says: Intended for joint applicant, this information is not required for individual account. Then the signature section says: If you intend to apply for joint credit, the undersigned shall be jointly and severally liable for any and all credit extended from time to time.

We have an auditor who says we are in violation of Reg B because of this and not having them show by initialing that they want joint credit.

Thoughts? Is it sufficient the way we have it?

Well, it has to be separate from any attestation regarding the correctness of the information provided on the application, but other than that there are a number of ways to skin a cat, or so they say.

Can someone help me find the Second Quarter 2010 Fed Connection message via the Kansas City Federal Reserve that has been mentioned?