We qualify under the Small Creditor Temporary Balloon-Payment Qualified Mortgage Rules. Thereby, exempting us from the balloon payment prohibition in section 32 for HCM. However, since a HCM has a higher points and fees threshold than the Temporary Balloon Payment QM rules, does this mean that we can make the HCM as long as it meets the otherwise required ATR standards, but would not be considered a QM and therefore would not have even the rebuttable presumption of compliance?
In other words, can a HCM (HOEPA) loan ever be a QM?
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