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#2254086 - 05/18/21 10:17 PM Investment Property Loans
Shih_Tzu_Lvr Offline
Member
Joined: Nov 2011
Posts: 86
Are investment property loans subject to ATR QM

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Ability to Repay/Qualified Mortgage Rule
#2254097 - 05/19/21 12:23 PM Re: Investment Property Loans Shih_Tzu_Lvr
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
Generally, investment properties are usually exempt from Regulation Z because they usually have a "business" purpose (which is exempt under 1026.3(a)) and, therefore, are often not subject to ATR/QM rules because they are exempt from all parts of Reg Z. That said, the term "investment property" isn't defined and I've seen some personal "investment properties" that are absolutely subject to Reg Z (and QM/ATR).

What you need to do is to determine if your loan is exempt from Reg Z or not. If the loan is exempt, ATR/QM won't apply.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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