A business credit card application states "minimum of one guarantor" above the "guarantor information" section. My read of Reg B tells me that if it's our policy to require a guarantor for a credit card for a business or corporation, this is ok. However, I think we'd run into a problem with a sole proprietorship, as we cannot require a guarantor in this instance unless the individual applying for credit does not meet our credit guidelines. And in that instance, we cannot dictate who that should be. Am I reading into this correctly? Anyone see other issues with this requirement?

I think you're over-reading the application, which appears designed for a corporate entity (Inc, Corp, LLC, PLC, et) rather than a commercial loan to an individual. Walking it through, a sole proprietor guarantees a loan to his/her company by default.

The application is intended to suit the need for any type of business applying for a business credit card. I agree that a sole prop does guarantee their own loan, however we have another FI claiming this is an issue under Reg B. Trying to determine if we need to modify the app to alleviate any concerns. Appreciate your thoughts, as well as any others that may be out there.

I agree - you are over thinking it. Joe Blow dba Joe's Mowing applies for a credit card. The card is issued to "Joe's Mowing" and Joe Blow guarantees the card.