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When a loan is up for renewal, are we required to obtain evidence of joint intent? Or is that required only at the initial application? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

When a loan is up for renewal, are we required to obtain evidence of joint intent? Or is that required only at the initial application?

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Yes, Regulation B requires creditors to collect evidence of joint intent anytime there is an application for an extension of credit, including an application for a renewal. Regulation B defines the term “extension of credit” to include a “refinancing or other renewal of credit,” as well as “the continuance of existing credit without any special effort to collect at or after maturity).”

For resources related to our guidance, please see:

  • Regulation B, Official Interpretations, 12 CFR 1002, Paragraph 7(d)(1), Comment 3 (“A person’s intent to be a joint applicant must be evidenced at the time of application. . . . .”)
  • Regulation B, 12 CFR 1002.2(f) (“Application means an oral or written request for an extension of credit . . . .”)
  • Regulation B, 12 CFR 1002.2(q) (“Extend credit and extension of credit mean the granting of credit in any form (including, but not limited to . . . the refinancing or other renewal of credit . . . or the continuance of existing credit without any special effort to collect at or after maturity).”)