The new Integrated Disclosure revised definition of a balloon payment at 1026.37(b)(5) could have had a negative impact on single pay subordinate lien loans under IC 24-4.5-3-402.

I contacted the DFI this morning and below is the response I received (paraphrased):

We do not want to require refinancing of a single pay transaction with no less favorable terms just because Reg Z now requires creditors to inform consumers that a single payment loan includes a balloon payment feature.

This response will, for now anyways, allow us not to have to treat single pay subordinate lien loans as a balloon payment under IN statutes when the Integrated Disclosures become effective on 8/1/15.