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A branch manager asks about a loan file because a HELOC will provide funds for the down payment on the same dwelling. What should happen?

Correct Answer

A) 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
Include the HELOC payment in the ATR analysis
B
Treat the requirement as satisfied by experience rather than the rule that governs the file.
C
Apply the rule only after a regulator requests the file.
D
Treat the compliance requirement as optional because closing is near.

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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