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An MLO is originating a mortgage for a borrower who has irregular income from freelance work. Under the ATR rule, which of the following approaches best satisfies the income verification requirement?

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Correct answer: Use two years of federal tax returns and bank statements to document average income

The ATR rule (12 CFR §1026.43(c)(4)) requires creditors to verify income using reasonably reliable third-party records. For self-employed or freelance borrowers, two years of federal tax returns — often supplemented by bank statements — is the standard method for documenting irregular income, as it represents a reliable historical record. Client letters are not third-party financial records and do not meet the verification standard. Projected future earnings are speculative and not permissible for income verification. Stated income alone explicitly violates the ATR verification requirement.

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