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During intake, the file has borrower statements but no verified ability-to-repay analysis. What is the best compliant response?

Correct Answer

A) 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
Verify repayment ability before consummation using reliable records
B
Treat the compliance requirement as optional because closing is near.
C
Continue processing without correcting the disclosure, licensing, compensation, or consumer-protection issue.
D
Ignore the issue if the borrower orally agrees to continue.

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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