Is it acceptable to have customers provide joint intent by the use of typed initials, or are they required to be handwritten initials? We have some lenders that have the application on their computers and complete with the borrower.

They are marked based on the officer asking the borrowers questions and the application is signed by the borrowers - not sure what else you need.

The only thing Regulation B says on documenting joint intent is this:

"3. Evidence of joint application. A person's intent to be a joint applicant must be evidenced at the time of application. Signatures on a promissory note may not be used to show intent to apply for joint credit. On the other hand, signatures or initials on a credit application affirming applicants' intent to apply for joint credit may be used to establish intent to apply for joint credit. (See Appendix B.) The method used to establish intent must be distinct from the means used by individuals to affirm the accuracy of information. For example, signatures on a joint financial statement affirming the veracity of information are not sufficient to establish intent to apply for joint credit."

As Randy said, as long as your lenders are completing this based off what the applicant says, that should be sufficient. Sure, an auditor or two may prefer that the initials be written from the applicant, but there is nothing absolute in Regulation B that requires the signatures to be written. In my opinion, its really no different than a telephone or electronic application.

This is a case where forms vendors created compliance confusion in their attempt to avoid any potential liability for Reg B violations. We never needed a separate line or box to be initialed on a loan application to evidence intent to apply jointly. If you've got an application form that is signed by all applicants, all you need is a line above the application signature lines that says: "If signed by multiple applicants, we intend to apply jointly." The whole joint intent rule was put in place to combat commercial loan situations where there was no written application form and lenders were saying "Well both spouses signed the financial statement so we assumed they were applying jointly and that's why we required the spouse to sign the loan."