We used to make demand loans and have many still on our books. Under the new rules, do we have to go thru ATR (we are a small servicer) every time one matures and is rewritten? Are those rewrites considered refinances? or modifications? The loans are structured as fixed rate with balloon. The whole point of demand loans was the convenience of not having to go thru a new set of underwriting/disclosures/appraisals at each maturity (cheaper and faster for our customers). It also gave customers a "line of credit" against which they could borrow.
Thanks for your input.