How is the Debt to Income (DTI) ratio in the Calculation Results section on the
Calculations page calculated differently than the DTI shown on the ATR/HOEPA/HPML/QM
page?
The DTI within the Calculation Results is determined by dividing Total All
Monthly Payments from the Monthly Housing Expense and Ratios section by
Total including Base Income in the Monthly Income section on the Financial
Analysis page.
The DTI within the Ability to Repay section is determined by summing Monthly
Mortgage Related Obligations, Covered Transaction Monthly Payment, All Other
Loans, and Monthly Debt Obligations and dividing that total by Current/Expected
Income.
The DTI within the Qualified Mortgage section is determined by summing Covered
Transaction Monthly Payment, Monthly Mortgage Related Obligations, All other
Loans Monthly Payment, and Monthly Debt Obligations, and dividing that total by
Current/Expected Income.
Depending on your organization's policies and practices, it is possible that all
instances of the DTI are the same in some transactions. The income and monthly
mortgage payment used in the DTI calculation are the factors that will most
commonly cause a difference in these DTI instances. This is due to the different
regulatory requirements for Ability to Repay (ATR) and Qualified Mortgage (QM).
The Covered Transaction Monthly Payment calculation requirements and income
requirements for ATR are found in regulation Z 1026.43(c)(2) and 1026.43(c)(5).
The Covered Transaction Monthly Payment calculation requirements and income
requirements for QM are found in regulation Z 1026.43(e) and Appendix Q.