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Originally posted in Compliance Masters Group Forum by cnakashige:
I’m not sure if this questioned has been addressed or not for preferred rate loans. These discounted loan rates are offered for employees, automatic payments, and to those clients with a larger deposit relationship. If an employee, for example, had a 1/4% discount on the the current 10-year 3.75% rate (rate of 3.50%), under the revised Reg Z ATR rules do we underwrite to the 3.75% rate and not the discounted rate? If the rate does increase (employee resigns or automatic payment ceases), can the loan still be considered a QM?
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