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An MLO is reviewing procedures for a case where a HELOC will provide funds for the down payment on the same dwelling. What is the proper handling?

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
Use funds from an undisclosed account without updating the file.
C
Resolve the Simultaneous loan in ATR analysis issue with the fee tolerance exception that does not fit the facts.
D
Use unexplained large deposits as verified assets.

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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