Re. 226.36
Open Saturdays and Sat. loan payments are credited on next business day. New principle dwelling secured loans have a disclosure on the note telling them Fri. after 4PM & Saturday payments are credited on the next business day (usually Monday). Is a small sign posted at the teller windows sufficient to cover existing applicable loans that never got the disclosure? Or do we need to mail them to existing customers? Looking for opinions/practices.

This is from the commentary to that section and then my opinion on how it is applied (I could be wrong though):

1. Crediting of payments. Under Sec. 226.36(c)(1)(i), a mortgage servicer must credit a payment to a consumer's loan account as of the date of receipt. This does not require that a mortgage servicer post the payment to the consumer's loan account on a particular date; the servicer is only required to credit the payment as of the date of receipt. Accordingly, a servicer that receives a payment on or before its due date (or within any grace period), and does not enter the payment on its books or in its system until after the payment's due date (or expiration of any grace period), does not violate this rule as long as the entry does not result in the imposition of a late charge, additional interest, or similar penalty to the consumer, or in the reporting of negative information to a consumer reporting agency.

I interpret this to mean if you receive a payment on Saturday, you can post it Monday, but the payment needs to be credited or effective dated to Saturday so they incur no additional interest on the loan. I think the language is a bit confusing because the writers were trying to help banks out since most don't have operations open on Saturdays, but the main idea is the date the bank physically receives the payment (in person, by mail, etc.) is the date the consumer must be credited. You can post it later and effective date it back to the date the payment was made, but you can't impose a posting/crediting delay that costs the consumer money in the form of late fees, additional interest, etc.

SkiDoo - It's snowing in AK in the mtns. Thanks
That's all understood. We don't want to credit the payment on Saturdays and the reg allows for this IF we tell the customers. So our existing new loans now have the disclosure (no credit on Sat), but what about existing customers? How to get them the word short of a mailing. Wondering if the sign at the teller window would suffice.
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Oh - sorry I guess I went off on the wrong tangent, huh? As far as the sign, I don't know but I think when this change happened we did a combination periodic statement message and for people who don't get periodic statements we sent a letter, but that was so long ago I might be confusing notices!

I will PM you!

OK thanks. Probably the best route to take. Mailing.