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A compliance review finds that the file has borrower statements but no verified ability-to-repay analysis. What should the MLO do next?

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
Document that records, reports, and required notices was reviewed, but take no required corrective action.
B
Verify repayment ability before consummation using reliable records
C
Use an informal exception and leave the required record unchanged.
D
Let production goals override the required verification, disclosure, license, or record step.

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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