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A lender is considering a mortgage application where the borrower's debt-to-income ratio is 45%, but all other QM requirements are met. The loan amount is within conforming limits. If the lender can demonstrate the borrower has substantial compensating factors, what type of loan could this be?

Correct Answer

C) Non-QM loan that meets ATR

Since the DTI exceeds 43%, this cannot be a General QM loan under 12 CFR 1026.43(e)(2)(vi). However, the lender can still originate the loan as a non-QM loan if they can demonstrate compliance with the ATR rule through compensating factors under 12 CFR 1026.43(c)(7), such as residual income or assets.

Answer Options
A
General QM loan
B
Small Creditor QM loan
C
Non-QM loan that meets ATR
D
Seasoned QM loan

Why This Is the Correct Answer

Since the DTI exceeds 43%, this cannot be a General QM loan under 12 CFR 1026.43(e)(2)(vi). However, the lender can still originate the loan as a non-QM loan if they can demonstrate compliance with the ATR rule through compensating factors under 12 CFR 1026.43(c)(7), such as residual income or assets.

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