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When to Obtain Joint Intent

Can you confirm joint intent must be collected at application and not at the time of a completed application?

The Commentary to §1002.7(d)(1) #3 states, A person’s intent to be a joint applicant must be evidenced at the time of application… Notice it states “application” NOT “completed application”. Application is defined in §1002.2(f) as, an oral or written request for an extension of credit that is made in accordance with procedures used by a creditor for the type of credit requested. Thus, joint intent needs to be documented at the time any oral or written request for credit is made.
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First published on 08/13/2017

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