Dan, I have to disagree. The intent of the change to Reg. B with respect to joint applications was to protect certain classes of applicants from the presumption that they were applying for joint credit; for example, a married woman submitting a joint financial statement to support an application. The mere fact that she submitted the joint f/s is not sufficient evidence that she is applying for joint credit; hence the need for the separate affirmative statement. The Federal Register – 2003, page 13150 – talks about this in more detail.
With the above in mind, I believe “contemporaneously” means, in the context of 7(d)(2) in the OSI, “beginning at the same time or during the same period of time” and not the exact instant. Intent; and not whether individuals visit the bank together or at different times is the determining factor.
The commentary states at 7(d)(3), “A person's intent to be a joint applicant must be evidenced at the time of application.” In the father-son example, depending on the situation, they could be joint-applicants or an applicant and cosigner (or guarantor). In the following 2 scenarios; I’m a co-applicant (a/k/a joint applicant) in the first and a cosigner in the second:
1-My son (who’s now out of college and working full-time) and I apply for joint credit to purchase a classic car. He applies on Monday, I visit the bank on Tuesday; in this case we are co-applicants. It’s clear we intend to purchase the car together; and, on Monday he signed the joint application statement.
2-My son (who is in college, working part-time) applies for a car loan. Knowing he’s a full-time college student with limited income – I visit the bank with him and tell the loan officer I’m willing to sign the loan if need be. On the basis of the bank’s lending policy my son doesn’t’ qualify, so the loan officer takes me up on my offer; in this case I’m a cosigner or guarantor (depending on the bank’s procedure). Whether or not the bank provides the co-signer notice depends on whether or not my name will be on the title to the car (and perhaps, state law).
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Merely my opinion...