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I am trying to find out if the new ATR rules affect pre-qualifications and if so how. Can a pre-qualification still be done without meeting all of the ATR requirements or is that not acceptable?
IMO, pre-qualifications won’t change much. They are not a guarantee of a loan, rather an preliminary indication of what someone might qualify for if they meet the underwriting criteria. Just to be sure we are talking about the same thing, check out this info pertaining to pre-qual vs pre-approvals on the CFPBs website: https://www.consumerfinance.gov/askcfpb/127/whats-the-difference-between-being-prequalified-and-preapproved-for-a-mortgage.html
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