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A borrower-facing employee is unsure what to do when a HELOC will provide funds for the down payment on the same dwelling. What is the correct response?

Correct Answer

C) 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 based only on borrower preference and document the file later.
B
Rely on sales practice rather than required verification, disclosure, or documentation.
C
Include the HELOC payment in the ATR analysis
D
Use a manager exception instead of the required federal mortgage rule.

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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