Debt to income ratio – I have a question regarding DTI when there is a change in circumstance. We have a few loans this month that have a change in circumstance in which the loan amount is increased. I need to clarify if we should be reporting the DTI from the initial approval, or the DTI from after the CIT.

The regulation states that we use what was relied on in making the credit decision. I was thinking that we would use the “initial approval” DTI. Can you let me know your thoughts?

You mean you can raise the loan amount after initial approval and not go back and get the loan reapproved considering the new loan payment amount required and the impact that has on the ATR?

You should be using the DTI from after the changed circumstance as this was ultimately the DTI you used to approve the loan. Hopefully this is documented in your loan file, as Randy point out...