Originally made a loan for major renovations to primary dwelling and set up as 12-month construction loan with intentions of them obtaining permanent financing elsewhere. Now, they are requesting we do permanent financing 61 month term with balloon payment. We are not doing a new note but rather a Change In Terms (CIT). Are "renewals" (change in terms note) covered by ATR? I have no doubt if we were starting with a new note this would have ATR but since we are using a CIT, I'm in doubt.
Opinions are mine and subject to change frequently