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Is there any regulations other than HOEPA/HCM rules that prevent a 5 year balloon loan?
We will be eligible to make Temp. Balloon Payment QMs until the sunset date but currently we only offer 7 year balloons. Senior Mgt. is considering offering a 5 year balloon (except for HOEPAs) until the temp rules expire. Also, the balloon payment has to hit at 61 months or the balloon has to be considered in ability-to-repay?
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