Thoughts? 1). As there is no threshold for DTI under this exemption, loans that meet ATR general and the points limits would be a QM? Other than doing a 61 month balloon (using fully indexed and fully amortizing pymts) that is (ATR losn as bank not small creditor) If so, if bank made a loan that was an ATR and not a QM due to fees, wouldn't that open up fair lending issues as most in portfolio was a small services QM?
2) bad loans on books should be modified prior to maturity or bank should workout loan (also exempt from ATR guidelines-TDR). Otherwise, loan cannot be made as it doesn't fit ATR guidelines?
3) if policy states 45% DTI but made an exception to 46%, would this fall as an ATR loan only as it didn't meet internal guidelines (bank set threshold, not regulation).
Thanks and sorry if answers are in different posts! My head is just spinning :-)