Keep in mind also that, if your bank and the loan meet the criteria (which include asset size and loan parameters, including holding in portfolio) of Section 101 of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 (Public Law No: 115-174), you only have to consider income, debt, and financial resources of the borrower and the only stipulation about that consideration is that it doesn't have to be done in accordance with Appendix Q or any successor regulation and that multiple means of documentation are allowed. Under this, the loan will be deemed to be a Safe Harbor QM loan which means ATR cannot be raised as a defense to any collection action on that loan.
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Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions