I remember about 12-14 years ago the FDIC put out a bulletin addressing this issue. I've tried to find it several times but have been unable to locate it. It may have been a SCANS bulletin that was put out by the Chicago Region and those were not posted on the FDIC web site.
Now with that disclaimer the bulletin in a nutshell said by assigning debt where debt does not exist could/would present fair lending issues. The bank's underwriting should be based on what is known, not what they speculate may happen.