This is my understanding of the AMTPA:
The purpose of this rule is to put lenders in various states on an even playing field in terms of products they offer by creating preemptions of state laws that restrict those products, provided you follow the rules of the AMTPA.
The rules, such as the commitment letter rule, apply only to those lenders wishing to employ the preemption from state law. (See p 44241, center column.)
For example, if our state banned all three year balloons, AMTPA would allow them, provided you gave the commitment letters as described in 1004.4(b).
Since Illinois law only prohibits balloons less than 15 year for the high risk loans as defined in title 38, 1050, the AMTPA commitment letter provision is not something we would ordinarily have to worry about.
So, we can still make balloons, at least until the final "ability to repay" rule comes out.
This is only my reading of the rule, and my opinion is not based on any authoritative source.
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I thought getting old would take longer.