According to Section 1026.43(c)(2)(ii), a creditor must verify a consumer’s employment status only if the creditor relies on the consumer’s employment income in determining ATR. Will a consumer’s paystub or tax returns suffice for determining the “employment status” or do we actually need to also contact the employer to get oral verification of employment? What about self-employed and employment status?
A paystub or tax return would work for income verification, but IMO does not verify employment status. These are reflective of employment in the past not currently. The regulation 1026.43(c)(3) states you must have verify employment status using third party records or you can verify it verbally with the employer but it needs to be well documented.