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#1889447 - 01/23/14 04:04 PM Some renewals expected not to qualify under ATR
BTrahan Offline
New Poster
Joined: Jul 2009
Posts: 18
Louisiana
We are a small creditor making balloon loans under the exemption, we are expecting to have some of our old loans maturing and not being able to qualifiy under the ATR rules because of self employment, change in jobs, loss of income, etc. On refinances with no new fund how are other small creditors handling these loans? Also, if we have to finance the escrow premiums this will be new money how will you hanlde these?

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Ability to Repay/Qualified Mortgage Rule
#1889475 - 01/23/14 04:23 PM Re: Some renewals expected not to qualify under ATR BTrahan
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
We are doing our best to modify prior to maturity. There will be some that are fully refinanced anyway and it just is what it is...can't really be helped and we will not be opting for foreclosure unnecessarily.
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My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1889477 - 01/23/14 04:24 PM Re: Some renewals expected not to qualify under ATR BTrahan
dblack Offline
Gold Star
Joined: Feb 2008
Posts: 263
AL
Modifications on ones with no new funds.

If you have to advance money I think you will just have to document extremely well. The intent of the regs wasn't to make you foreclose on performing loans.
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#1889495 - 01/23/14 04:40 PM Re: Some renewals expected not to qualify under ATR BTrahan
BTrahan Offline
New Poster
Joined: Jul 2009
Posts: 18
Louisiana
If we have to advance new funds the loan will not be a QM since it does not meet the ATR rules, are yall coding the non-QM loans on your system with a code to tract how many Non-QMs you have on your books?

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#1889522 - 01/23/14 04:59 PM Re: Some renewals expected not to qualify under ATR BTrahan
RR Becca Offline
Power Poster
RR Becca
Joined: Sep 2004
Posts: 5,245
out of the frying pan...
Other way around for us - we're going to flag the QMs since we expect to have less of them than the non-QMs.
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#1889556 - 01/23/14 05:23 PM Re: Some renewals expected not to qualify under ATR BTrahan
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
We have to mark within our platform system whether it is or isn't a QM.

We feel like all of our new originations will be ATR and QM qualified.

I don't see advancing new money on non-ATR-qualifiable refinances...I only see being able to do 'work-outs' to continue amortizing out the loan.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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