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.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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