Perhaps they are hanging their hat on this... 1) does not specify that you must consider a balloon payment.
They would not have safe harbor, however.
(A) A loan with a balloon payment, as defined in § 1026.18(s)(5)(i), using:
(1) The maximum payment scheduled during the first five years after the date on which the first regular periodic payment will be due for a loan that is not a higher-priced covered transaction; or
(2) The maximum payment in the payment schedule, including any balloon payment, for a higher-priced covered transaction;
My opinion only. Not legal advice.
Say you'll haunt me - Stone Sour