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Intent to Proceed on Commercial Purpose Loans?

Question: 
Are we required to have an intent to proceed on commercial purpose loans?
Answer: 

by Randy Carey:

If the loan is made to individuals - yes. If individuals are involved because your policy requires that officers, directors, or shareholders guarantee the loan to a business entity - no.

Answer: 

by David Dickinson:

I agree with Randy, but want to clarify. Joint Intent documentation is not a consumer purpose requirement. It applies to all application in which there are 2 or more applicants. If XYZ Co and ABC, Inc. apply jointly, you need documentation to satisfy §1002.7(d) to prove you didn't require either of these applicants to jointly apply.

Answer: 

by Dan Persfull:

The title of the thread and the question itself refers to "intent to proceed". There is no regulatory requirement that I am aware of that requires the applicant's intent to proceed be documented for business purpose loans.

If the poster was actually inquiring about "joint intent" then Randy and David provided the necessary requirements.

First published on 06/09/2019

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