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#2231747 - 02/26/20 05:11 PM Reg B Joint Intent - 2 questions
mdog76 Offline
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What best way to document Joint intent on a phone app?

If a lender uses two apps instead of a single app, would that signify joint intent?

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Lending Compliance
#2231750 - 02/26/20 05:17 PM Re: Reg B Joint Intent - 2 questions mdog76
Skittles Offline
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1. The lender should notate on the application that he/she obtained joint intent.
2. No - and why would they use 2 applications? You would still have to ask the question and notate the answer.
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#2231759 - 02/26/20 05:44 PM Re: Reg B Joint Intent - 2 questions mdog76
mdog76 Offline
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Not sure why they used two apps instead of one, but we will let them know need to use one app and notate joint intent.

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#2231768 - 02/26/20 06:19 PM Re: Reg B Joint Intent - 2 questions mdog76
Skittles Offline
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In a previous life the mortgage company would do two applications if the applicants weren't married - however that is treating applicants different under marital status.
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#2231958 - 02/27/20 08:50 PM Re: Reg B Joint Intent - 2 questions mdog76
Gertie Offline
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When we have 2 applications for 1 request for credit, we have both applicants sign a separate piece of paper acknowledging intent to apply jointly. Examiners have never indicated a problem with it.

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#2231963 - 02/27/20 09:01 PM Re: Reg B Joint Intent - 2 questions mdog76
Skittles Offline
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Gertie - I'm curious - why/when do you have two separate applications?
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