This might be an underwriting question rather than a regulatory question I'll give it a go. If a real estate secured loan is made to 2 borrowers and only 1 is on title can require that both be on title. And it we can and the change in title is not done until closing, do we give both the notice of right to rescind?

If a real estate secured loan is made to 2 borrowers and only 1 is on title can require that both be on title.

Who is on title to the property is not up to the lender. You determine if the borrowers can afford the loan and you get the owner of the property to pledge the collateral. Who owns the property has no impact on the loan and changing ownership could have serious tax consequences for the borrower and is really not a concern of the lender. Having a valid note and security interest is your only concern.

Sorry that I posted under the wrong thread. Should have been under Reg Z.

Thank you rlcarey. I appreciate your feedback.

FWIW, I agree with Randy. It's not our place to dictate ownership in property.