Do you require unmarried applicants who apply jointly for a mortgage loan to complete separate 1003 applications, or do you allow the applicants to complete one 1003?
If they are applying as joint applicants, we would only complete one 1003, that way both of the applicants could sign the joint credit disclosure at the top of the application.
We require 2 applications due to the fact that our investors require this, and our Loan operating system will not pull separate credit for nonmarried applicants. ( you can not pull joint credit on unmarried borrowers). To my knowledge there is not a regulatory reason to separate the applications under Reg B. Since we utilize a feature in our LOS to pull credit we do separate applications to be in compliance with the FCRA-FACT Act.
My bank uses a single 1003 for any and all who want to apply jointly, and that would be my recommendation.\n\nAn applicant's marital status should have no impact on your bank's application procedures. If you require non-married joint applicants to do more work (complete separate forms), while married joint applicants complete just one form - - - That could be a Fair Lending concern of treating applicants differently based on marital status.\n\n
If the applicants have extensive, separate asset/liability information, you would need two apps for them to have enough room for the information. They can then sign the intent for joint credit disclosure. When it comes to a credit report, our system allows for two single applicants to be run through as a "joint" report. In fact,the systems have to in order to not be 'unfair', since single applicants were getting charged more, separately, for credit reports, than for a married couple receiving a joint report.
It is my understanding that you cannot pull a joint credit with unmarried applicants. Our system also will pull a joint credit when you put both applicants on the same application. In regards to the cost, our credit bureau contacted us in 2010 to offer same pricing per pull for joint and for single due to the fair lending questions that have rose as of the past couple of years. Our joint pulls are exactly double of our single pulls. Our regulatory agency is the FDIC. We have had an examination in the past 6 months and there was nothing mentioned in regards to the separate applications or in regards to FCRA/FACTA. We recieved glowing comments. I don't know if that matters or not, but just wanted to toot our horn a little so to speak. \n
I agree with Kevin. You cannot make an unmarried applicant do something you wouldn't make a married couple do (fill out separate applications or pay for multiple credit reports) without having a Reg B violation. Unmarried joint applicants should be treated the same as married joint applicants.
We allow them to complete one 1003 in most instances.
WE use a single 1003 application for those applying jointly, married or umarried. We recently underwent a Fair Lending Review this past Ausgust and this was part of a discussion with the FDIC examiner.