I happened to see the following question in the "Anonymous" section and thought it might be a good one to copy to this thread...perhaps Bec's question and the following one could be answered together?
Our bank has used 1.5% of the fully funded HELOC for the monthly payment used to qualify. The actual required payment during the draw period is interest only.
Questions: Under ATR, is this an issue? Also, if we use the preceding described approach for calculating a payment on our HELOC's but take the credit report payment amount [which is usually interest only] on other bank's HELOC's when underwriting other requests, is that permissible...or could it be deemed discriminatory?
Thank you for your input.