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A quality-control reviewer flags a case because the file has borrower statements but no verified ability-to-repay analysis. What correction is appropriate?

Correct Answer

B) Verify repayment ability before consummation using reliable records

Lines 207-214; 12 CFR 1026.43(c)(1). The ATR rule requires a pre-consummation determination based on reliable information, not unsupported statements or collateral alone. Therefore, the correct response is "Verify repayment ability before consummation using reliable records".

Answer Options
A
Use the consumer-facing workflow as a reason to postpone the required compliance step.
B
Verify repayment ability before consummation using reliable records
C
Skip the rule because the consumer-facing workflow appears routine.
D
Assume records, reports, and required notices is outside compliance review because no fee has been charged yet.

Why This Is the Correct Answer

Lines 207-214; 12 CFR 1026.43(c)(1). The ATR rule requires a pre-consummation determination based on reliable information, not unsupported statements or collateral alone. Therefore, the correct response is "Verify repayment ability before consummation using reliable records".

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