CoreLogic provides third party verification and full documentation to help you comply with the ATR and the CFPB's audit requirements. CoreLogic has the compliance solutions you need, when you need them, delivered how you want them, from the platforms you already use.
The QM and ATR Rules require you to make a “reasonable and good faith determination at or before the consummation that the consumer will have a reasonable ability to repay the loan according to its terms.” You now have two related compliance challenges.
You must develop processes that assure the “production” of compliant loans.
You must have the ability to document such compliance to a regulator.
Whether or not you plan to originate QM-compliant loans, as of January 10, 2014, every loan that you originate must comply with the 8 ATR requirements.
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