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In a mortgage origination file, the file has borrower statements but no verified ability-to-repay analysis. Which action should be taken?

Correct Answer

D) 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
Treat the requirement as satisfied by experience rather than the rule that governs the file.
B
Apply the rule only after a regulator requests the file.
C
Treat the compliance requirement as optional because closing is near.
D
Verify repayment ability before consummation using reliable records

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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