The OSC for 7(a) is for home equity plans. Perhaps the better bet is OSC 7(b)(10)-3: "3. Accrued finance charges allocated from payments. Some plans provide that the amount of the finance charge that has accrued since the consumer’s last payment is directly deducted from each new payment, rather than being separately added to each statement and therefore reflected as an increase in the obligation. In such a plan, the new balance need not reflect finance charges accrued since the last payment."
Last sentence suggests that accrued finance charges exclude the accrued interest due...
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From the end spring new beginnings.
Pliny the Elder