Question:
I’m not sure how to handle deferred student loan payments. I have a borrower that is working as a teacher and stated that her student loans would be paid for by the state. Does Appendix Q state that I can in essence ignore these debts?
Answer:
The bank can exclude them if they can show written evidence that they are not due until after 12 months from closing. Otherwise, they would need to be included, unfortunately, as set out here:
- Projected Obligations
- Debt payments, such as a student loan or balloon-payment note scheduled to begin or come due within 12 months of the mortgage loan closing, must be included by the creditor as anticipated monthly obligations during the underwriting analysis.
- Debt payments do not have to be classified as projected obligations if the consumer provides written evidence that the debt will be deferred to a period outside the 12-month timeframe.
https://www.consumerfinance.gov/policy-compliance/rulemaking/regulations/1026/Q/#5-1-a
Compliance Alliance offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com.
Not a member? Learn more about membership with Compliance Alliance by attending one of our live demos:
Compliance rules and regulations change quickly! For timely compliance updates, subscribe to Compliance Alliance’s email newsletters.
