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I was reading over the small entity compliance guide for ability to repay and on page 14 at the top it says “Copies of Tax-return transcripts or payroll statements can be obtained directly from the consumer or from a service provider, and need not be obtained directly from a government agency or employer, as long as the records are reasonably reliable and specific to the individual consumer” I thought these records had to come directly from a third party? We will be attempting to make the Small Creditor Portfolio QM, so does this mean we can continue to get copies from our customers as long as they are reasonably reliable?
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