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Commercial Debt ATR/QM

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  • #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?

    #11616
    rcooper
    Member

    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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