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Calculating DTI Ratio On New Consumer Loan

Question: 
If escrowed, are taxes and insurance included in the mortgage payment amount when calculating the debt-to-income DTI ratio on a new consumer loan?
Answer: 

by Dan Persfull:

(2) Basis for determination. Except as provided otherwise in paragraphs (d), (e), and (f) of this section, in making the repayment ability determination required under paragraph (c)(1) of this section, a creditor must consider the following:

(v) The consumer's monthly payment for mortgage-related obligations;

(8) Mortgage-related obligations mean property taxes; premiums and similar charges identified in ยง 1026.4(b)(5), (7), (8), and (10) that are required by the creditor; fees and special assessments imposed by a condominium, cooperative, or homeowners association; ground rent; and leasehold payments.

Answer: 

by Jim Bedsole:

Minor clarification: The provisions cited by Dan under 1026.43 only apply to certain consumer-purpose dwelling secured transactions. The original question is not clear on that point, mentioning only "new consumer loan". For calculation of DTI on a consumer loan NOT secured by a dwelling, what gets included in the "mortgage payment" would be a matter of loan policy for your institution. You will want to make sure you are applying whatever standard you choose consistently.

First published on 03/19/2017

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