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- Hi, Iamp;#39;m Glenn Gimble, and this is my colleague Elizabeth Khalil. When underwriting a loan that is not a qualified mortgage, creditors must consider the following eight factors, and verify the information used in making the credit decision, using amp;quot;reasonably reliable third-party records.amp;quot; Before we go through the eight factors, letamp;#39;s talk about what is meant by amp;quot;reasonably reliable third-party records.amp;quot; The ATR/QM rule itself, and Official Commentary, have an illustrative list of examples. And itamp;#39;s important to note that, despite the name, amp;quot;third-party recordamp;quot; includes some of the creditoramp;#39;s own records for accounts it holds for the consumer. It can include such records as savings accounts, retirement accounts, and so on, that the consumer has with the creditor. So even though the rule calls the records amp;quot;third-partyamp;quot; records, many of the bankamp;#39;s own records can be used. - Now
