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#2198073 - 11/13/18 02:45 PM Joint Intent & Credit Reports
Anonymous
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Is it a violation of Reg B to pull credit reports on co-applicants if they have not indicated in any way that they are joint applicants? I have an application (submitted via internet) with joint applicant information but no signature or initials indicating that they intend to apply jointly. I am in a community property state if that makes any difference.

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#2198078 - 11/13/18 03:14 PM Re: Joint Intent & Credit Reports Anonymous
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
The joint intent requirement of Reg B and the permissible purpose to obtain a credit report under the FCRA are unrelated IMO.
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#2198095 - 11/13/18 04:45 PM Re: Joint Intent & Credit Reports swiggles
Fiddlesticks Offline
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Joined: May 2015
Posts: 62
Is joint intent needed if the application is denied or withdrawn?

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#2198099 - 11/13/18 04:55 PM Re: Joint Intent & Credit Reports Anonymous
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,220
Galveston, TX
That is a chicken or the egg question. Gathering joint intent is to prove that the signatories on the debt obligation are proper. If there is no loan, there are no signatories. However, the regulatory commentary indicates that joint intent should be determined at application.

Paragraph 7(d)(1).

3. Evidence of joint application. A person's intent to be a joint applicant must be evidenced at the time of application.
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#2198101 - 11/13/18 04:58 PM Re: Joint Intent & Credit Reports Anonymous
swiggles Offline
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swiggles
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Joint intent must be obtained at the time of application.

see the OSC to 1002.7....7(d)(1)3.
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