Posted By: Anonymous
5 Yr Balloon Payment 60 vs. 61 months - 10/12/21 12:56 PM
My team is telling me they have always been told to issue a 5 yr balloon with 61 months payment vs 60. Can anyone tell me where in the regulation this is stated?
Posted By: Dan Persfull
Re: 5 Yr Balloon Payment 60 vs. 61 months - 10/12/21 08:51 PM
Review 1026.43. It has to do with the ATR.
2. First five years after the date on which the first regular periodic payment will be due. Under § 1026.43(c)(5)(ii)(A)(1), the creditor must determine a consumer's ability to repay a loan with a balloon payment that is not a higher-priced covered transaction using the maximum payment scheduled during the first five years (60 months) after the date on which the first regular periodic payment will be due. To illustrate: