Am I correct in thinking that a "bridge" loan product with a 24 month interest only term followed by a balloon payment in the 25th month would
a.) Be subject to ATR as it is over 12 months in term and
b.) Require the borrower to qualify using the balloon payment as it is the highest payment in the first 5 years of the loan?

I would agree with you, yep.

Thanks....time to go pop this one!