Yes. The mother is not materially benefitting from the loan. See the definition of "cosigner" in Reg A. 227.12(b)(1),(2)&(3). An examiner "caught us" on a couple of these during an exam....didn't have any trouble locating the loans in which the "co-borrower" met the definition of "co-signer" under Reg AA.
_________________________
The more you sweat in training, the less you bleed in battle.......