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A self-employed borrower provides bank statements instead of tax returns for income verification. Under what circumstances would this alternative documentation be considered acceptable for QM compliance?

Correct Answer

C) When used as part of a comprehensive analysis meeting ATR requirements

Under the ATR/QM rule (12 CFR 1026.43), while there are specific documentation requirements for General QM loans, alternative documentation can be used if the creditor makes a reasonable, good faith determination of the consumer's ability to repay based on verified and documented information, including comprehensive analysis of the borrower's financial situation.

Answer Options
A
When the borrower's accountant certifies the bank statement income
B
When the bank statements show consistent deposits for 24 months
C
When used as part of a comprehensive analysis meeting ATR requirements
D
Bank statements alone are never acceptable for QM loans

Why This Is the Correct Answer

Under the ATR/QM rule (12 CFR 1026.43), while there are specific documentation requirements for General QM loans, alternative documentation can be used if the creditor makes a reasonable, good faith determination of the consumer's ability to repay based on verified and documented information, including comprehensive analysis of the borrower's financial situation.

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