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QMs and ITINs

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Question: 
Can a mortgage loan made to a non-US citizen using an ITIN instead of an SSAN be a qualified mortgage loan, if it meets all of the criteria?
Answer: 

Regulation Z does not cover foreign nationals that are not resident aliens, who would have a Social Security Number.

Official Interpretation
1(c) Coverage
1. Foreign applicability. Regulation Z applies to all persons (including branches of foreign banks and sellers located in the United States) that extend consumer credit to residents (including resident aliens) of any state as defined in §1026.2.

First published on 10/23/2022

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