Since payment deferrals/extensions fall under an extension of credit under Regulation B, does joint intent apply? We do not obtain applications or get a credit report for payment deferrals/extensions. The customer makes the verbal request and they sign the payment extension agreement.

Thank You

the customer makes the verbal request

Would that not be an oral request?

(f) Application means an oral or written request for an extension of credit that is made in accordance with procedures used by a creditor for the type of credit requested.


We do require joint intent and all parties to the loan must sign the deferral agreement.

Thank You.

I have a general joint intent question. If two applicants submit separate applications for one loan, we are still required to acknowledge they are applying jointly, correct? This is something we have used a separate "Intent to Apply for Joint Credit" form for, but I am also wondering if each applicant could simply initial their respective application in the provided joint applicant box?

I see no problem with it.

Thank you.

Is there required wording for the disclosure of joint intent? Our application has a box to check that say “Joint” and then two lines for the customer to sign, would this be sufficient? Or should it read “I (we) intend to apply joint credit” and then the two lines?

I am not sure why any lender would choose to use a format other than what is provided in the Model Application forms found in Regulation B.