Reg B Joint App Form Required on Entity Loan?

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Question:

Our bank does not require applications for commercial loans booked to entities. If the entity requires more than one signature, is a Reg B joint credit application form required? Is a Reg B joint credit application form required when you have personal guarantees on an entity loan?

Answer:

Corporations, partnerships, guarantors, etc. meet the definition of an applicant for the purposes of Reg. B section 1002.7(d).

Unless you have a lending policy that requires all closely held corporation loan requests be guaranteed by the officers, or a guarantor is otherwise an underwriting condition of the loan request you must establish joint intent for all loan requests, business or consumer.

First published on BankersOnline.com 5/13/13