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We are running consumer loans (not talking about RE loans) under an actual 365 interest base. It has come under question internally because of how the payments credit in a situation where the customer is delinquent. In some instances, the entire payment may credit toward interest, if the accrued on the day of payment is at least as high as that payment. There has been discussion that this is not permissible and that all payments for any consumer transaction should have a principal portion just as 30/360 mortgages do. Please shed light on this for me and point me to regulation if possible.
Thank you,
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