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A creditor discovers 45 days after closing that they failed to verify the borrower's employment as required under ATR rules, though the borrower was actually employed as stated. What is the potential liability?

Correct Answer

B) ATR violation regardless of the borrower's actual employment status

Under 12 CFR 1026.43(c)(2), creditors must make a reasonable and good faith determination of repayment ability based on verified information. Failure to verify employment as required constitutes an ATR violation regardless of whether the information was accurate, as the violation is in the process, not the outcome.

Answer Options
A
No liability since the borrower was actually employed
B
ATR violation regardless of the borrower's actual employment status
C
Liability only if the borrower defaults within three years
D
Curable violation if corrected within 60 days of discovery

Why This Is the Correct Answer

Under 12 CFR 1026.43(c)(2), creditors must make a reasonable and good faith determination of repayment ability based on verified information. Failure to verify employment as required constitutes an ATR violation regardless of whether the information was accurate, as the violation is in the process, not the outcome.

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