I have searched the lending thread and the infovault and can't seem to find anything specifically on point...is an applicant who applies as "Joe Smith, d/b/a Joe's Grocery" considered to be a consumer entity or a commercial entity for adverse action purposes?

Look to the definitions of "business credit" and "consumer credit" in Reg. B.

A d/b/a would fall under consumer credit. Another point along the same lines, at my bank, our loan officers want to file UCC's with the d/b/a Joe's Grocery, which I don't think is necessary. I say to just file under their indivdual name, i.e. Joe Blow. After all, there is no seperation of assets between the individual and d/b/a.

FWIW, I disagree with Texas boy that a d/b/a would fall under consumer credit. It could, I suppose, but it depends on the purpose of the loan.

After thinking about it, Great Blue, you probably are correct. After all, a "doing business as" does have the word business in it. I guess I need to go back and read the Reg.

I actually just went and asked our president and senior loan officer and they agreed that it would fall under business purpose. I am still going to read the reg to satisfy myself, but it does make sense. Thanks for pointing that out Great Blue. I am not sure why I was thinking that in the first place!