Are there exemptions for ATR on VA IRRL and FHA Streamline Refi's? The FHA guide shows that for non-credit qualifying streamline refi's, an abbreviated 1003 can be used that does not collect income, employment, etc and DTI is not required. I'm having trouble figuring out how that is allowable considering ATR/QM requirements. Is it 1026.43(e)(4) that would support that? I'm sure it's something I'm missing and any help is appreciated.

1026.43(e) Qualified mortgages—(1) Safe harbor and presumption of compliance—(i) Safe harbor for loans that are not higher-priced covered transactions and for seasoned loans. A creditor or assignee of a qualified mortgage complies with the repayment ability requirements of paragraph (c) of this section if:

(A) The loan is a qualified mortgage as defined in paragraph (e)(2), (4), (5), (6), or (f) of this section that is not a higher-priced covered transaction, as defined in paragraph (b)(4) of this section.......

1026.43(e)(4) Qualified mortgage defined—other agencies. Notwithstanding paragraph (e)(2) of this section, a qualified mortgage is a covered transaction that is defined as a qualified mortgage by the U.S. Department of Housing and Urban Development under 24 CFR 201.7 and 24 CFR 203.19, the U.S. Department of Veterans Affairs under 38 CFR 36.4300 and 38 CFR 36.4500, or the U.S. Department of Agriculture under 7 CFR 3555.109.

Thanks so much!