[Sandy]

We have a TRID loan that on the borrower’s credit report it shows off 4 student loans that were charge off in November 2017. There is no payment listed on the credit report. Do we account for any type of payment, maybe an estimated monthly payment, on the ATR worksheet for these?

[jholzknecht]

This largely a matter of bank policy. Some lenders will not make a loan to a borrower with a recent charge-off. The regulation does not contain a ATR worksheet. Apparently your bank has built one or adopted one developed by a third party. If your policy allows loans to an applicant with a recent charge-off, then determine if your policy requires the charged-off debt to be included in the debt on your worksheet.

[jholzknecht]

This largely a matter of bank policy. Some lenders will not make a loan to a borrower with a recent charge-off. The regulation does not contain a ATR worksheet. Apparently your bank has built one or adopted one developed by a third party. If your policy allows loans to an applicant with a recent charge-off, then determine if your policy requires the charged-off debt to be included in the debt on your worksheet.

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