I know, this subject just won't go away; sorry. Our mortgage lenders asked me some time ago about whether they needed to get the second applicant on the phone(if joint phone application) agreeing to a joint application in order for the financial institution to pull a credit report. I told them that was not required as along as they had a permissible purpose (applying for credit). Now they are asking me if they need to have the second applicant come on line just to tell them that they are agreeing to be a joint applicant (to show the intent) or if the primary applicant stating it will be a joint application is sufficient. I do not feel the second applicant needs to come "on line", that when they do come in and sign the application, you will then have your documentation. Am I on the right track? Help!

The reg does NOT stipulate in what manner the evidence needs to be obtained; only that the evidence to support the intent to apply jointly needs to be documented "at application." Therefore, documentation after the fact is irrelevant. It is during the phone app that your loan officers need to be asking questions to determine joint intent and then simply note it on the app or in a "memo to file."