Wondering if anyone else has encountered this. We have a borrower whose credit report shows aggregate student loan debt in excess of $195,000 is in repayment, but has only aggregate monthly payments of $201.00. These monthly payments appears to be insufficient to cover the repayment of this debt.

They may be in deferment, set up as an interest only for every loan (which still seems low), or a special repayment plan is set up. What is your question? Are you looking to find out how to use the payments for ATR?

It seems that the monthly payment reported on the credit report is extremely low. Would it not make sense to obtain the current contractual terms of the student loans to ascertain when there will be adjustments to the monthly payments.

We use the credit report to determine the borrower's current debt obligations. Further, 1026.43(c)(3)(iii) gives the following guidance...

(iii) For purposes of paragraph (c)(2)(vi) (Borrower's DTI) of this section, if a creditor relies on a consumer's credit report to verify a consumer's current debt obligations and a consumer's application states a current debt obligation not shown in the consumer's credit report, the creditor need not independently verify such an obligation.

I checked with my underwriters, and they confirmed that they use the payment reported on the credit report as the 3rd party verification. If no amount is listed, than they use 2% of the outstanding balance (per FHLMC guidelines).