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Separate Banks, One Owner - Late Charge Procedures
Answer by Dan Persfull, BOL Guru
Guru Bio
Question: I have a client bank that has just purchased another institution. The two banks have been under the same holding company, but now will be the same bank. For purposes of late charges imposed, must both banks use the same late charge procedures as far as when they are imposed and how much or is it just a matter of disclosure, as long as two separate procedures are disclosed, two modes of implementation will be deemed acceptable?
Answer: State law dictates how much and when you impose late charges.
First published on BankersOnline.com 3/31/08
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