I want to make sure my assessment of Ability to Repay and a small creditor portfolio QM is correct.

As a small creditor, the bank must perform a good-faith ATR evaluation that includes the eight ATR underwriting factors from 1026.43(c)(2)-4). We are not required to follow Appendix Q. We must consider the consumer’s DTI or residual income, but the rule sets no specific threshold (i.e 43%). As long as these guidelines are followed, the loan is a QM.
Is this correct?

Thank you.

“The wise know their limitations; the foolish do not.”
Benjamin Hoff, The Tao of Pooh