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Commercial Debt ATR/QM

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  • August 16, 2017 at 10:52 am EDT #11608
    mdunker
    Member

    We are having a discussion as far as do we count Commercial Debt in the ATR/QM calculation. We are a small creditor under ATR it states we have to consider the consumers current debt obligations. Does this include any commercial debt weather that be in the consumers personal name or business name?

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  • August 17, 2017 at 2:54 pm EDT #11616
    rcooper
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    It says generally “current debt obligations” and does specify consumer debt nor exclude commercial debt, so yes I would include any commercial debt obligations as well.

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