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#138359 - 12/10/03 09:05 PM Reg B applications
Anonymous
Unregistered

Am I correct that the changes affect all credit: consumer, business & ag? Specifically I am concerned with the requirement for affirmatively indicating desire for joint credit. Our commercial & ag departments don't use applications? Do we need a seperate form completed?

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Lending Compliance
#138360 - 12/10/03 09:51 PM Re: Reg B applications
JSD Offline
Platinum Poster
JSD
Joined: Oct 2000
Posts: 512
USA
ABA had a phone briefing and this was a topic discussed. The joint application issue was discussed and some of the called in questions were about how to comply with this requirement. A joint financial statement does not constitute a joint application. It requires more than a JT. F.S. to be considered a joint application.
Other evidence is needed. You must get an indication - signature or initials.
Procedures will need to be modified - either at point of application or during the application process.
consumer requests are easy b/c of application but business does not have 'an application' usually. Some recommended that a separate notice be provided and signed by the business applicants. IT MUST BE DISTINCT.
The statement that is usually on the last page of the application is attesting to the accuracy of information (at the bottom of the application) and they sign the statement is not acceptable for intent of applying for joint credit.
For on-line applications there is not much guidance, but it was recommended that you can use the board model form and have a box that the applicant can click on so a window pops up and explains exactly what joint credit/application means.
For phone apps it was recommended to create a script to be read to make clear to both parties how they want to apply and at closing have them check & initial a block indicating that they are applying for joint credit on a form/disclosure. The moderators stated that the regulators plan to monitor this new requirement very closely.

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