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Before closing, the team discovers that a HELOC will provide funds for the down payment on the same dwelling. What is the safest compliant answer?

Correct Answer

B) Include the HELOC payment in the ATR analysis

Lines 207-214; 12 CFR 1026.43(c)(2)(iv) and 1026.43(c)(6). A known simultaneous HELOC affects monthly obligations and must be considered for repayment ability. Therefore, the correct response is "Include the HELOC payment in the ATR analysis".

Answer Options
A
Proceed with the file before updating required application or underwriting information.
B
Include the HELOC payment in the ATR analysis
C
Use a sales preference instead of documented loan-file requirements.
D
Treat preliminary or incomplete information as final approval.

Why This Is the Correct Answer

Lines 207-214; 12 CFR 1026.43(c)(2)(iv) and 1026.43(c)(6). A known simultaneous HELOC affects monthly obligations and must be considered for repayment ability. Therefore, the correct response is "Include the HELOC payment in the ATR analysis".

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