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Under ATR, if we want to rely on income that is only shown on a tax return, do we have to get the tax return transcript (or a copy of the tax return that shows it was filed)? Simply getting a copy of the tax return from the customer will not suffice? I just know that it can take a while to get the transcript…
The final regulations give you quite a bit of flexibility in verifying income. You may use a transcript, but you may also get a copy of the tax return that was filed with the federal or state government directly from the consumer. The proposed regulations took a stricter stance on this issue, but the CFPB lightened up with the final rule published earlier this year. This doesn’t remove your responsibility to determine that the information is reasonably reliable.
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