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In a mortgage origination file, a HELOC will provide funds for the down payment on the same dwelling. Which action should be taken?

Correct Answer

D) 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
Let production goals override the required verification, disclosure, license, or record step.
B
Apply the rule only after a regulator asks specifically about asset verification.
C
Treat the rule as waived because all parties want the file to move faster.
D
Include the HELOC payment in the ATR analysis

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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