Reply To: Small Creditor QM DTI Loan Policy Exception


As you stated, there isn’t a DTI ceiling for the small creditor QM option. As long as you consider the DTI and verify the debt and income in accordance with 1026.43(e)(5)(B) then there isn’t a limit on the DTI, which means you could make an exception to your policy. Just remember that exceptions to your loan policy increases fair lending risk. Exceptions should be infrequent and well documented.