The HPML repayment ability requirements are set to expire at 11:59pm on January 9, 2014 which means they won’t conflict with the ATR requirements when they become effective on January 10, 2014. Your bank can decide what DTI ratio they want to use. If you are making a general QM then the DTI must not exceed 43% – if you exceed that you will not have a QM under the general QM rule, even if you make an exception to your policy.
