ATR/QM Balloon Payment Exception Policy
Updated 06/12/2026
This policy summarizes the requirements of the ATR/QM balloon payment exception
Rule: 12 CFR Part 1026 – Truth in Lending (Regulation Z)
Keywords: Truth in Lending, Regulation Z, TILA, ATR, Mortgage, Balloon Payment
1/23/2026 Updated to reflect 2026 HOEPA/QM thresholds.
6/12/2026 – Note: On May 19, 2026, President Trump issued Executive Order 14406, Restoring Integrity to America’s Financial System. Subsequently, FinCEN, jointly with the FDIC and OCC, issued Joint Advisory FIN-2026-A002 addressing BSA/AML risks associated with non-work-authorized populations, and the CFPB issued its Statement on Ability to Repay and Immigration Status regarding the consideration of immigration status and repayment risk in underwriting decisions. As of this writing, additional guidance regarding related credit-risk management expectations remains pending.
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