Reply To: ATR/QM and Balloon Loans


You can use the ATR rules or any of the QM rules for which you qualify. And you can use a different option for each loan if you choose – you aren’t required to choose the same option for all of your loans.

The options that allow you to make balloon loans are the general ability to repay rules – 1-26.43(c)(2), the temporary balloon QM – 1026.43(e)(6) or the balloon QM – 1026.43(f). Remember, that under the general ability to repay rules that a higher priced covered transaction (HPCT) requires you include the highest payment in the payment schedule (the balloon payment) in the payment calculation which will likely significantly increase the debt-to-income ratio and make it difficult for you to qualify borrowers under the ATR for higher priced covered transactions (HPCT).