Small Entity Making Only Portfolio Consumer Mortgages - Where a small, rural bank uses DSCR as an established method for determining the ATR for commercial business-for-self borrowers, would calculating a business-for-self borrower's DSCR, as opposed to DTI, be acceptable for ATR purposes? Based on bank history, a borrower with a DSCR ratio of X would be able to repay the loan under the terms of the note regardless of whether the loan is consumer or commercial. Thanks in advance for your input.

IMO, no...DSC ratios should be used for commercial specific property vs the income/cash flow produced BY a property, etc.

The following is a good article on the two calculations:

http://rosecityrealtyinc.wordpress.com/2012/08/30/dsc-the-kissing-cousin-of-dti/