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Compare a 25-year interest-only loan, a fully amortizing 30-year fixed-rate loan with level monthly payments and a 2% origination fee, a 20-year loan with a balloon in year seven, and a payment-option loan permitting negative amortization. Assuming all other General QM requirements are met and no balloon-payment exception applies, which has permissible loan features?

Correct Answer

C) Only the 30-year fixed can be a qualified mortgage under this rule

C. Only the specified fully amortizing 30-year fixed-rate product has permissible features. Interest-only payments defer principal; negative amortization permits the balance to grow. The balloon feature is excluded on the stated facts. The remaining product amortizes fully through regular payments. Scope and exceptions: A fixed rate or a 2% origination fee alone does not prove QM status. All applicable points-and-fees, term, underwriting and pricing requirements still apply; the stem expressly assumes them. Non-QM does not automatically mean unlawful. Source: Section 1026.43(e)(2)(i)–(ii) and accompanying interpretations — https://www.consumerfinance.gov/rules-policy/regulations/1026/43/

Answer Options
A
The interest-only loan and the 30-year fixed can both be qualified mortgages
B
All 4 can qualify, since the features affect pricing and not QM status
C
Only the 30-year fixed can be a qualified mortgage under this rule
D
Only the 20-year balloon fails, because a balloon is the sole bar

Why This Is the Correct Answer

C. Only the specified fully amortizing 30-year fixed-rate product has permissible features. Interest-only payments defer principal; negative amortization permits the balance to grow. The balloon feature is excluded on the stated facts. The remaining product amortizes fully through regular payments. Scope and exceptions: A fixed rate or a 2% origination fee alone does not prove QM status. All applicable points-and-fees, term, underwriting and pricing requirements still apply; the stem expressly assumes them. Non-QM does not automatically mean unlawful.

Why the Other Options Are Wrong

Option A: The interest-only loan and the 30-year fixed can both be qualified mortgages

The interest-only product fails the principal-repayment requirement.

Option B: All 4 can qualify, since the features affect pricing and not QM status

These features affect QM eligibility, not merely price.

Option D: Only the 20-year balloon fails, because a balloon is the sole bar

Balloon payments are not the only disqualifying feature.

Exam Tip

Check payment structure separately from interest-rate type and total fees.

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