We have a customer that currently is a pastor, barber and draws Social Security. Last year he had two operations and was unable to work very much. His year to date employment makes his budget a 39.6% using all income, but we can not verify his past two year employment where he was not earning any income. He is applying for a HELOC to repair water damage to his home. Are there any exceptions for the case of an emergency?
Are you talking about the Qualified Mortgage requirements in Reg Z, 2016.43? If so, home equity lines of credit (open end) are exempt from the requirements. There are repayment ability verification requirements in HOEPA rule under 1026.34 for High Cost HELOCs.