B’s definition of “applicant” excluded guarantors. Douglas County Nat’l Bank v. Pfeiff, 809 P.2d 1100, 1102 (Colo.Ct.App.1991); Kevin A. Palmer & Michael H. Malin, Jr., ECOA, Regulation B, and the Spousal Guaranty: Recent Developments, 115 Banking L.J. 357, 359 (1998). The primary purpose of the 1986 amendment was “ ‘to give guarantors and similar parties standing to seek legal remedies when a violation occurs under § 202.7(d).’ ” Pfeiff, 809 P.2d at 1103 (quoting Final Rule Revising Regulation B, 50 Fed. Reg. 48,018, 48,020 (Nov. 20, 1985) (Official Staff Commentary)); see also Joel D. Stafford, Consumer Protection: The Equal Credit Opportunity Act: Guarantors as Applicants' — :Did the Cost of a Violation Go Up?, 40 Okla. L.Rev. 431, 442-43 (1987) [hereinafter “Stafford Article ”] (<HOLDING>). Consequently, for purposes of § 202.7(d), a
recognizing the amendment provides regulatory standing to a guarantor to sue for violations of regulation bs cosignature rules holding that plaintiffs lacked standing to sue holding that employers have standing to sue recognizing right of guarantor to contribution against coguarantors holding the same with respect to violations of the fifth amendment