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A processor asks how to handle a file where a HELOC will provide funds for the down payment on the same dwelling. Which response is most accurate?

Correct Answer

C) 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
Apply the rule only after a regulator requests the file.
B
Treat the compliance requirement as optional because closing is near.
C
Include the HELOC payment in the ATR analysis
D
Continue processing without correcting the disclosure, licensing, compensation, or consumer-protection issue.

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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