WE HAVE A CUSTOMER WHO WISHES TO APPLY WITH US FOR A MORTGAGE LOAN, HOWEVER THE CUSTOMERS INCOME IS FROM OUTSIDE OF THE US. WOULD WE TREAT THIS LIKE ANY OTHER BORROWER WHEN WE QUAILFY THE BORROWER ON THE ATR/QM BASIS? DO WE NEED TO DO ANYTHING DIFFERENT FOR THIS BORROWER?
We don’t believe you would treat it any differently. You are still going to want verification of the income as required under the ATR/QM rules (if it is taxable it should show on tax returns or similar form of documentation). Both Fannie Mae and Freddie Mac address foreign income as acceptable and provide income verification requirements.