The structure has two phases and one balance. During the interest-only period the payment equals the interest accruing on the full original principal. Because none of it is applied to principal, the balance at the end of the period is the same as the balance at the beginning. The loan then amortizes that unchanged balance over the remaining years of the term, which is where the payment shock comes from: on a thirty-year loan with a ten-year interest-only period, the principal that would have had thirty years to repay now has twenty.
This is not a hidden fee or a penalty, and describing it that way misses what the borrower actually agreed to. It is the direct consequence of not having repaid anything. Nor is the total interest paid simply higher by the length of the deferral: it is higher because the balance on which interest accrues stayed at its opening level for the whole interest-only period rather than declining.
No equity is built from payments, which changes the risk profile. On a conventional amortizing loan a borrower accumulates equity two ways, from principal repayment and from price appreciation, and the first of those is contractual. During an interest-only period only the second operates. A borrower who needs to sell or refinance during that period is entirely dependent on what the market did, and if prices have fallen, the balance is unchanged while the value is not. That combination is what turns an interest-only borrower into an underwater one faster than any other common structure.
Why it is a non-qualified mortgage, and what that means. Under 12 CFR 1026.43(e)(2)(i)(B), a qualified mortgage under the general definition must provide for regular periodic payments that do not "allow the consumer to defer repayment of principal," except as provided in the balloon-payment paragraph. An interest-only feature is precisely a deferral of principal repayment, so the loan falls outside that definition. The other routes do not rescue it: the seasoned-loan definition at (e)(7) requires a fixed-rate mortgage with fully amortizing payments, and the balloon-payment route at (f) requires scheduled payments that are substantially equal, calculated on an amortization period. The temporary balloon provision at (e)(6) applies only to covered transactions "for which the application was received before April 1, 2016," so it is not a live option. Loans defined as qualified mortgages by HUD, the Department of Veterans Affairs or the Department of Agriculture under (e)(4) follow those agencies' own program rules.
For a borrower the practical consequences of non-qualified status are three. The lender still owes the full ability-to-repay determination under 12 CFR 1026.43(c), so the underwriting is not looser. What the lender loses is the presumption of compliance that qualified-mortgage status carries, which makes lenders selective about who they will write one for. And the loans are harder to sell, so fewer institutions offer them, terms are tighter, and pricing reflects a thinner market. Interest-only mortgages did not disappear after 2008; they moved into portfolio lending, where a bank keeps the loan and can look at an individual borrower's circumstances.
Where it genuinely fits. Three situations recur. A borrower whose income is lumpy rather than low, such as someone paid largely in commission or an annual bonus, may prefer a low required payment and voluntary principal payments when the money arrives. A borrower with a genuinely short and certain holding period may not care about amortization at all. And a borrower with a large, illiquid asset arriving on a known date may be bridging to it. What these have in common is that the borrower has a specific plan for the principal. The structure fails when the plan is "prices will rise" or "I will refinance," because both of those are assumptions about a market rather than facts about a balance sheet.
How the disclosure states it. Regulation Z requires the Loan Estimate to disclose the loan product's features, and 12 CFR 1026.37(a)(10)(ii)(B) provides that if one or more regular periodic payments may be applied only to accrued interest and not to principal, the creditor must disclose that the loan product has an "Interest Only" feature. Separately, because the payment on such a loan changes after closing for a reason other than a rate adjustment, the form carries an Adjustable Payment table, and 12 CFR 1026.37(i)(1) requires that table to give an affirmative or negative answer to the question "Interest Only Payments?" and, where the answer is yes, the period during which those payments are scheduled. So the question does not require interpreting a note: it is answered in two places on a form the borrower receives within three business days of applying.