Skip to content
BOL Conferences
Thread Options
#179539 - 04/14/04 02:51 PM Co-signer---intent required??
Dabba Offline
Member
Dabba
Joined: Sep 2003
Posts: 62
TN
Am I right in saying that a co-signer on a loan would have to sign the intent language for Reg B just as a co-borrower would since they would be covered under the definition of borrower under Reg B? Thanks.

Return to Top
Lending Compliance
#179540 - 04/14/04 03:01 PM Re: Co-signer---intent required??
Terry Offline
Gold Star
Terry
Joined: Sep 2001
Posts: 314
Midwest
That's my take. I refer to the definition of applicant in 202.2(e). The last sentence in that section says that for purposes of 202.7(d) regarding signatures of spouses the term appliant "includes guarantors, sureties, endorsers and similar parties." However, others on this site have recently expressed different opinions on this issue.
_________________________
All statements are my own and not necessarily those of my employer.

Return to Top
#179541 - 04/14/04 03:22 PM Re: Co-signer---intent required??
Beagles22 Offline
Power Poster
Joined: Jan 2004
Posts: 3,626
State of confusion
I would, at this time, say better to be safe than sorry. I know that our vendor for all of our forms updated everything this week with a new intent form even for the 1003 as the Wisconsin Bankers Association spoke to the FDIC and their 'interpretation' is that we can do what we or our legal departments think is appropriate but they are making the forms available on all of our systems for processing.
_________________________
Going to church doesn't make you a christian any more that standing in your garage makes you a car.

Return to Top
#179542 - 04/14/04 05:06 PM Re: Co-signer---intent required??
Terry Offline
Gold Star
Terry
Joined: Sep 2001
Posts: 314
Midwest
I'm going to have change my position on this. I just spoke with an attorney at the Fed Board in Washington who gave me a different answer. It's explained in detail HERE.
_________________________
All statements are my own and not necessarily those of my employer.

Return to Top

Moderator:  Andy_Z