Answer:
Although Reg. B is specific to spouses, to ignore other relationships which may exist would, in my opinion, treat these borrowers differently. The intent of Reg. B is to ensure similar treatment of applicants throughout the credit transaction. This includes credit reporting if you are doing this.
At the heart of Reg. B is the purpose, including a statement that one requirement is that if you report credit histories, it must be in the names of both spouses on the account.
There is also Section 202.10(b) stating that "If a creditor furnishes credit information to a consumer reporting agency concerning an account designated to reflect the participation of both spouses, the creditor shall furnish the information in a manner that will enable the agency to provide access to the information in the name of each spouse."
First published on BankersOnline.com 8/16/04
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