We are in the middle of a Consumer Lending review and noticed that our single payment loans are missing late fee language on the Disclosure Stmt. Is there some regulation or possibly a law prohibiting late fees on these?
Regulation Z requires the disclosure of late charges in the appropriate TIL disclosure form. Whether a late charge can be imposed, the amount of the late charge, and the length of any grace period are issues addressed under state law, and usually are detailed in state usury statutes. Check with your general counsel or with your state banking association regarding the fees allowed in your state.