Can anyone point me to how to handle addressing who is a cosigner vs. a co-borrower now that Reg. AA has been repealed? I used to rely on the Reg. AA definition of cosigner. We're dealing with people being added to a loan as a co-borrower that are not receiving benefit of the loan (check is payable to only one party) and the loan officer was relying on the "co-borrower's" credit worthiness.
I have a loan officer that doesn't want to believe me that a "co-borrower" that doesn't have access to the loan proceeds should be considered a cosigner and not only a co-borrower.