Will any of the new CFPB rules affect modifications of consumer dwelling secured loans? We no longer make new RESPA/Reg. Z loans but we still have some on our books that we would possibly modify. We do not (do not want to) escrow, have any HPMLs etc.

Modifications from what I understand are exempt from the QM and AtR requirements.

Would we be able to do modifications with balloon payments?

As far as i can tell from what has been released so far yes you can. But it doesn't mean the CFPB won't 'finalize' the final rules again.

from the regulatory text -
In addition, § 1026.43 does not apply to any change to an existing loan that is not treated as a refinancing under § 1026.20(a).