I have a question and am seeking guidance from multiple sources. I am also seeking verbiage from the regulation (if there is any) and not just a best practice. I would like guidance from all directions if that makes sense.

I have found two discussions/questions from Bankers Online regarding documenting joint intent and GMI. Reg B Joint Intent Notice thread from 2009-2010 and GMI reporting for HMDA purposes on 4-11-11.

Here is my situation:
Loan application for joint borrowers on a HMDA reportable loan request. Primary borrower applied in person and gave the co-borrower information and also gave the GMI for co-borrower. The primary borrower signed and dated the application and then the loan officer wrote "information provided by husband" on the co-borrower signature line and joint intent line. I have found nothing that says this is not acceptable. It is not our normal procedure, but it is how the lender documented at the time. She is new to taking applications.

From my research of the reg., and other comments, I have found this to be acceptable. The regulation, as far as I've read, states no specific means as to how an institution should document joint intent or GMI in this type of situation other than it's an application documentation item. To me, it is a procedural process.

Thank you in advance for any and all input.

Just my opinion, but I don't regard "Information provided by husband" as joint intent from the wife. How do you know she is even aware of the loan application--and the fact that she will be liable as a borrower--at that point?

I am referencing comments made by David Dickinson and Dan Persfull in two separate posts as my sources that it is ok for one borrower to "represent" a co-borrower.

If either of you can comment on this and let me know if this opinion still stands it would be greatly appreciated.

I'm not savvy enough to figure out how to reference the two posts on here so that's why I gave the subject title and date of both in my first post.

Thanks again!

If you could provide a link to the threads, that would be more helpful. Just googling your descriptions above I can't find them to see what you are referring to.

I have looked at both links provided above and still agree with what I and Dan stated.

Manimal stated "Just my opinion, but I don't regard "Information provided by husband" as joint intent from the wife. How do you know she is even aware of the loan application--and the fact that she will be liable as a borrower--at that point?"
Let me put this in a scenario. I call the bank and say "my wife & I would like to apply for a loan." At your bank Manimal, does the loan officer say something like "I'm sorry, but I can't take your word for that. I'll need to talk to your wife and hear from her directly."?

The new HMDA proposal even says one person can complete GMI for an absent joint applicant not present [Comment #4 to §1003.4(a)(10)(i) - page 540 of the proposal]. I don't think this is a change to the current HMDA rules, only further clarification of what they want under today's rules.

Thank you David. I appreciate your response.