Reg Z ATR –Ability to Repay and Third Party Records

Compliance > Regulation Z - TILA > Ability to Repay / Qualified Mortgages
Q:  Under the standard ATR rules, for the purposes of verifying information, what is meant by a third party record?
A:  A third party record refers to:
  • A document or other record prepared or reviewed by an appropriate person other than the consumer, the creditor or mortgage broker, or an agent of the creditor or mortgage broker;
  • A copy of a tax return filed with the IRS or state taxing authority; or
  • If the consumer is an employee of the creditor or mortgage broker, a document or other record maintained by the creditor or mortgage broker regarding the consumer’s employment status or employment income.

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