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During intake, a HELOC will provide funds for the down payment on the same dwelling. What is the best compliant response?

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
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
Assume another jurisdiction approval automatically cures this file.

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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