On September 25th, Carl Anderson, Chief Counsel at the PA Department of Banking, issued a letter intended to clarify section 613 of the PA MVSFA. Mr Anderson's letter basically states that regardless of the number of days to first payment on a retail installment contract, the bank cannot charge more than 30 days interest. So, we can go, for example, 45 days to first payment, but only charge for 30. Not going to go over well with the finance department. Or, we can stand firm and always go exactly 30 days to first payment. This is not good for customer relations.

This has the Automotive Association and banks in a quandry as there seems to be mixed emotions as to the accuracy of this letter. I'm searching for opinions/comments with regards to this.

As a community bank in PA, I'm wondering who got a copy of this letter or received notification about the changes to the MVSFA. We were forwarded another bank's notification to a director/dealer today. I haven't been able to locate any helpful data.

In response to the DOB's interpretive letters dated 7/25/03 and 9/25/03, our bank's indirect auto finance area has decided not to accept contracts that are more than 30 days to the first payment. Our field reps have indicated that most of the other finance sources (both banks and non-banks) are implementing that same restriction.

Sure thing. Once the page appears, page down to section 613.

http://www.banking.state.pa.us/banking/cwp/view.asp?A=1296&QUESTION_ID=528209

Update: the PA DOB just issued another interpretive letter dated 11/7/03 clarifying that the 30 day "day count" means calendar days. I didn't see it on the DOB website this A.M. but it should be there before too long.